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The Fourth Amendment exists to protect the right of the people to be free from unreasonable searches and seizures by government officials. Iowa Const. art. I, § 8 also contains a search and seizure clause that is virtually identical to the Fourth Amendment. Accordingly, the Iowa Supreme Court usually interprets the scope and purpose of Iowa Const. art. I, § 8 to track with federal interpretations of the Fourth Amendment.
On December 20, 2001, teachers and administrators at Muscatine High School attempted to complete an annual pre-winter break cleanout of the lockers assigned to each student at the school. The students were asked three to four days before the cleanout to report to their locker at an assigned time to open it so a faculty member could observe its contents. The general purpose of the cleanout was to ensure the health and safety of the students and staff and to help maintain the school's supplies. Accordingly, faculty assigned to examine the lockers kept an eye out for overdue library books, excessive trash, and misplaced food items. They also watched for items of a more nefarious nature, including weapons and controlled substances. The cleanout functioned as expected for approximately 1400 of the 1700 students at the school. However, a sizeable minority--including the appellee, Marzel Jones--did not report for the cleanout at their designated time. The next day, two building aides went around to the lockers that had not been checked the day before. Acting pursuant to rules and regulations adopted by the school board, the aides opened each locker to inspect its contents. The aides did not know the names of the students assigned to the lockers they were inspecting. One of the lockers they opened contained only one item: a blue, nylon coat, which hung from one of the two hooks in the locker. Apparently curious about its ownership and concerned that it might hold trash, supplies, or contraband, one of the aides manipulated the coat and discovered a small bag of what appeared to be marijuana in an outside pocket. The aides then returned the coat to the locker and contacted the school's principal. After crosschecking the locker number with records kept by the administration, the principal determined the locker in which the suspected marijuana was found belonged to Jones. The principal and aides then went to Jones' classroom and escorted him to his locker. Jones was asked to open the locker and, after doing so, was further asked if anything in the locker "would cause any educational or legal difficulties for him." Jones replied in the negative. The principal then removed the coat from the locker. Jones grabbed the coat, struck the principal across the arms, broke free from him, and ran away. The principal gave chase and, after three attempts, captured and held Jones until the police arrived. The police retrieved the bag and determined that it held marijuana. Jones was later charged with possession of a controlled substance in violation of Iowa Code section 124.401(5) (2001). He subsequently filed a motion to suppress the evidence--the marijuana--obtained during the search of his locker. He claimed that the search violated his right to be free from unreasonable search and seizure pursuant to the Fourth Amendment of the United States Constitution and article I, section 8 of the Iowa Constitution. The lone witness at the suppression hearing was the principal of the high school, who testified about school policy relating to search and seizure and the events of December 20 and 21. The District Court granted the motion to suppress. It found that the school officials did not have reasonable grounds for searching Jones' coat pocket. The State filed a motion requesting the judge reconsider and alter his decision. The motion was denied.
Was the District Court's grant of a motion to suppress evidence obtained during the search proper?
The Iowa Supreme Court noted the essential purpose of Iowa Const. art. I, § 8, and U.S. Const. amend. 4, was to impose a standard of "reasonableness" upon the exercise of discretion by government officials in order to safeguard the privacy and security of individuals against arbitrary invasion. The Iowa Supreme Court applied the three-part analysis of the United States Supreme Court's opinion in Bd. of Ed. of Indep. Sch. Dist. No. 92 v. Earls, in determining the issue of whether a search of a student's locker was constitutional. Although the United States Supreme Court had not specifically addressed a search of students' lockers or desks, the Iowa Supreme Court concluded a student did have a legitimate expectation of privacy in a school locker. However, it was the character of the intrusion that was the deciding factor. The Iowa Supreme Court held the search of the contents of defendant's locker was not overly intrusive, given the nature of the school's concerns of maintaining a controlled and disciplined environment, in which the education of all students could be achieved.