Law School Case Brief
Hageman v. Goshen Cty. Sch. Dist. No. 1 - 2011 WY 91, 256 P.3d 487 (2011)
Because students who participate in extracurricular activities are already regulated more strictly, their reasonable expectations of privacy are even more limited than those of the general student population. Accordingly, the legitimate expectations of privacy are reduced for those students subject to drug testing under a school district's policy.
In an effort to address a perceived drug and alcohol problem among its students, defendant Goshen County School District No. 1 ("District") adopted a policy ("Policy") requiring all students in grades 7 through 12 who participated in extracurricular activities to consent to random testing for drugs and alcohol. Plaintiffs Hugh and Lee Hageman, on behalf of their minor children who were students at a school operated by the District, joined by numerous other parents and students, filed a declaratory judgment action in Wyoming state court against the District. Plaintiffs sought a determination that the Policy violated the prohibition against unreasonable searches and seizures under Wyo. Const. Art. 1, § 4. The District filed a motion for summary judgment, which the trial court granted. Plaintiffs appealed.
Was subjecting students involved in extracurricular activities to random drug and alcohol testing a violation of the prohibition against unreasonable searches and seizures under Wyo. Const. Art. 1, § 4?
The state supreme court affirmed the trial court's judgment. The court held that, while Wyo. Const. art. 1, § 4, protected public school students from unreasonable searches and seizures, the testing at issue was reasonable. Students were already subject to more stringent rules and regulations than adults and had limited expectations of privacy in the school setting. The District had a compelling interest in providing for the safety and welfare of its students and thus had a legitimate interest in deterring drug and alcohol use among students, and the Policy was rationally related to furthering that interest.
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