SAFFORD UNIFIED SCHOOL DISTRICT v. REDDING

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Case Basics
Docket No. 
08-479
Petitioner 
Safford Unified School District #1, et al.
Respondent 
April Redding
Advocates
(argued the cause for the petitioners)
(Assistant to the Solicitor General, Department of Justice, argued the cause for the United States as amicus curiae)
(argued the cause for the respondent)
Term:
Facts of the Case 

Savana Redding, an eighth grader at Safford Middle School, was strip-searched by school officials on the basis of a tip by another student that Ms. Redding might have ibuprofen on her person in violation of school policy. Ms. Redding subsequently filed suit against the school district and the school officials responsible for the search in the District Court for the District of Arizona. She alleged her Fourth Amendment right to be free of unreasonable search and seizure was violated. The district court granted the defendants' motion for summary judgment and dismissed the case. On the initial appeal, the U.S. Court of Appeals for the Ninth Circuit affirmed. However, on rehearing before the entire court, the court of appeals held that Ms. Redding's Fourth Amendment right to be free of unreasonable search and seizure was violated. It reasoned that the strip search was not justified nor was the scope of intrusion reasonably related to the circumstances.

Question 

1) Does the Fourth Amendment prohibit school officials from strip searching students suspected of possessing drugs in violation of school policy?

2) Are school officials individually liable for damages in a lawsuit filed under 42 U.S.C Section 1983?

Conclusion 
Decision: 7 votes for Redding, 2 vote(s) against
Legal provision: Fourth Amendment

Sometimes, fact dependent. No. The Supreme Court held that Savanna's Fourth Amendment rights were violated when school officials searched her underwear for non-prescription painkillers. With David H. Souter writing for the majority and joined by Chief Justice John G. Roberts, and Justices Antonin G. Scalia, Anthony M. Kennedy, Stephen G. Breyer, and Samuel A. Alito, and in part by Justices John Paul Stevens and Ruth Bader Ginsburg, the Court reiterated that, based on a reasonable suspicion, search measures used by school officials to root out contraband must be "reasonably related to the objectives of the search and not excessively intrusive in light of the age and sex of the student and the nature of the infraction." Here, school officials did not have sufficient suspicion to warrant extending the search of Savanna to her underwear. The Court also held that the implicated school administrators were not personally liable because "clearly established law [did] not show that the search violated the Fourth Amendment." It reasoned that lower court decisions were disparate enough to have warranted doubt about the scope of a student's Fourth Amendment right.

Justice Stevens wrote separately, concurring in part and dissenting in part, and was joined by Justice Ginsburg. He agreed that the strip search was unconstitutional, but disagreed that the school administrators retained immunity. He stated that "[i]t does not require a constitutional scholar to conclude that a nude search of a 13-year old child is an invasion of constitutional rights of some magnitude." Justice Ginsburg also wrote a separate concurring opinion, largely agreeing with Justice Stevens point of dissent. Justice Clarence Thomas concurred in the judgment in part and dissented in part. He agreed with the majority that the school administrators were qualifiedly immune to prosecution. However, he argued that the judiciary should not meddle with decisions school administrators make that are in the interest of keeping their schools safe.

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SAFFORD UNIFIED SCHOOL DISTRICT v. REDDING . The Oyez Project at IIT Chicago-Kent College of Law. 29 August 2014. <http://www.oyez.org/cases/2000-2009/2008/2008_08_479>.
SAFFORD UNIFIED SCHOOL DISTRICT v. REDDING , The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2000-2009/2008/2008_08_479 (last visited August 29, 2014).
"SAFFORD UNIFIED SCHOOL DISTRICT v. REDDING ," The Oyez Project at IIT Chicago-Kent College of Law, accessed August 29, 2014, http://www.oyez.org/cases/2000-2009/2008/2008_08_479.