Bd. of Educ. v. Earls

536 U.S. 822, 122 S. Ct. 2559 (2002)



The court generally determines the reasonableness of a search by balancing the nature of the intrusion on the individual's privacy against the promotion of legitimate governmental interests. In certain limited circumstances, the government's need to discover latent or hidden conditions, or to prevent their development, is sufficiently compelling to justify the intrusion on privacy entailed by conducting such searches without any measure of individualized suspicion. Therefore, in the context of safety and administrative regulations, a search unsupported by probable cause may be reasonable when special needs, beyond the normal need for law enforcement, make the warrant and probable-cause requirement impracticable.


Respondent students sued petitioner board of education, alleging that the board's drug testing policy was unconstitutional since the board failed to identify a special need for testing students who participate in extracurricular activities, and the policy neither addressed a proven problem nor required a showing of individualized suspicion of drug use, thus, it violated the students' constitutional right to be free from unreasonable searches.


Was the school policy of requiring students to undergo drug testing violative of the students’ constitutional right against unreasonable searches?




The United States Supreme Court held that the policy did not constitute an unreasonable search because it reasonably served the board's important interest in detecting and preventing drug use among its students. The board's general regulation of extracurricular activities diminished the expectation of privacy among students, and the board's method of obtaining urine samples and maintaining test results was minimally intrusive on the students' limited privacy interest. Further, the drug testing policy was a reasonably effective means of addressing the board's concerns about preventing drug use in the board's schools in the face of the evidence of increased drug use at the schools.

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