This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
A student at Farmington High School was observed smoking a cigarette on school grounds, violating school policy. The vice principal conducted a search of the student, during which marijuana was discovered in the student’s sock. The student argued that the search violated their Fourth Amendment rights.
Procedural History
- District Court, San Juan County: Denied the student’s motion to suppress the marijuana evidence, holding that the search was reasonable under the circumstances.
Parties' Submissions
- Appellant (Child): Argued that the search violated the Fourth Amendment because, after voluntarily relinquishing cigarettes and a lighter, there was no longer reasonable suspicion to justify a further search.
- Appellee (State): Contended that the search was reasonable under the Fourth Amendment, as the discovery of cigarettes and a lighter strengthened the suspicion that the student might possess additional contraband.
Legal Issues
- Was the search of the student justified at its inception under the Fourth Amendment?
- Was the scope of the search reasonable under the circumstances?
Disposition
- The Court of Appeals affirmed the district court’s decision, holding that the search was reasonable under the Fourth Amendment.
Reasons
Per Vanzi J. (Fry CJ. and Kennedy J. concurring):
- The Court applied the two-prong test from New Jersey v. T.L.O., requiring that a school search be justified at its inception and reasonable in scope.
- The search was justified at its inception because the student was observed smoking on school grounds, a violation of school policy, which provided reasonable suspicion to search for additional contraband.
- The discovery of cigarettes and a lighter strengthened, rather than dispelled, the reasonable suspicion that the student might possess additional contraband.
- The search was reasonable in scope, as it was minimally intrusive and appropriately tailored to the objective of finding contraband.
- The Court rejected the student’s argument that the discovery of cigarettes and a lighter eliminated reasonable suspicion, emphasizing that reasonable suspicion does not require absolute certainty.
The Court concluded that the search complied with the Fourth Amendment, and the evidence of marijuana was properly admitted.