Board of Education of Independent School District No. 92 of Pottawatomie County v. Earls case brief

Board of Education of Independent School District No. 92 of Pottawatomie County v. Earls case brief summary
536 U.S. 822 (2002)

CASE SYNOPSIS

Respondent students sued petitioner board of education, alleging that the board's policy requiring all students participating in extracurricular activities to submit to drug testing violated the students' constitutional right to be free from unreasonable searches. Upon the grant of a writ of certiorari, the board appealed the judgment of the United States Court of Appeals for the Tenth Circuit which held that the policy was unconstitutional.

CASE FACTS
The students contended 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.

DISCUSSION

• The United States Supreme Court held, however, 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.

OUTCOME

The judgment finding that the board's drug testing policy was unconstitutional was reversed.

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