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Vernonia School District v. Acton

Facts

A school district was experiencing a dramatic increase in student drug use. In particular, many of the students involved in the schoolโ€™s athletic programs were suspected of using controlled substances. The school district imposed a policy, applicable to all students participating in interscholastic athletics, subjecting them to random drug testing. The student and parents were required to sign a testing consent form before participating in an athletics program. The defendant was denied access to an athletics program as his parents refused consent.

Issue

Whether it is reasonable for a school district to require drug testing to participate in athletics programs?

Held

Yes. Student-athletes have a reduced expectation of privacy and the government has a compelling interest in protecting the students from the associated dangers.

Discussion

The Court has previously dispensed with the governmentโ€™s requirement of obtaining a warrant supported by probable cause in the past when a โ€œspecial needโ€ to conduct the search exists. The Court has found a โ€œspecial needโ€ in relation to public schools prior to this case, as well. See New Jersey v. T.L.O.. In this case, the Court found that โ€œ[L]egitimate privacy expectations are even less with regard to student athletes.โ€ They are subjected to a variety of communal observations and โ€œthey voluntarily subject themselves to a degree of regulationโ€ by joining the team. The Court balanced the reduced expectation of privacy the student-athletes receive in this environment with the governmentโ€™s compelling interest of protecting โ€œschool athletes, where the risk of immediate physical harm to the drug user or those with whom he is playing his sport is particularly high.โ€ In doing so, it found the school districtโ€™s requirements reasonable.

Citation

515 U.S. 646, 115 S. Ct. 2386 (1995)

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