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This case occurred in 1995 and is a landmark case for student athletes limited privacy.
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Case Analysis #2

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PRESENTATION OUTLINE

1.

CASE ANALYSIS

Vernonia School District 47J v. Acton
This case occurred in 1995 and is a landmark case for student athletes limited privacy.
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2.

FACTS ABOUT THE CASE

  • School research found high use of drugs with their student athletes
  • Concerned with risk of injury and overall health.
This case is looking at the 4th Amendment and if it extends to student athletes when being required to submit to a drug test. James Acton was a student at a school that "required all student athletes to take drug tests at the beginning of the season and on a random basis during the school year (Jacobs, 2008)." They had this policy as a way to curb drug use by their students.
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3.

FACTS ABOUT THE CASE

  • "Vernonia School District of Oregon adopted the Student Athlete Drug Policy which authorizes random urinalysis drug testing of its student athletes"
  • James Acton refused to take test and was denied participation.
The plaintiffs in this case was the family of James Acton. James wanted to try out for the football team but his family refused to let him take the drug test. They argued that "mandatory drug testing without suspicion of illegal activity constituted an unreasonable search under the Fourth Amendment (Jacobs, 2008)." The school suspended James from sports activity at the school because of his refusal to submit to mandatory drug test.
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4.

Legal Question:
"Does random drug testing of high school athletes violate the reasonable search and seizure clause of the Fourth Amendment?("Vernonia School District 47J v. Acton," n.d.)"

This case focus on if the fourth amendment extends to student athletes and protects them from having to take random drug tests.
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5.

LEGAL HISTORY OF THE CASE

  • The District Court denied the claims, but the Court of Appeals reversed
  • Supreme Court argued on March 28th,1995
  • Supreme Court Decided on June 26th, 1995
The case was tried and appealed before making it to the supreme court. The Supreme court supported original ruling that the drug policy was with in the rights of the school and does not violate the 4th amendment ("Vernonia School Dist. 47J v. Acton 515 U.S. 646 (1995)," n.d.)
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6.

RULINGS

  • "No. The reasonableness of a search is judged by "balancing the intrusion on the individual's Fourth Amendment interests against the promotion of legitimate governmental interests."
The court ruled 6-3 that the search is reasonable under the 4th amendment.
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7.

RATIONALE

  • Students during school hours "are subject to greater control than over free adults("Vernonia School District 47J v. Acton," n.d.). "
The judges felt that students in school hours and under school supervision are more limited under the 4th amendment. this is especially true for student athletes since they "must follow rules that don't apply to other students (Jacobs, 2008)"
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8.

RATIONALE CONTINUED...

  • "The urine samples are negligible since the conditions of collection are similar to public restrooms ("Vernonia School District 47J v. Acton," n.d.)."
They upheld that the test were only viewed by a few administrators and the test is not very invasive. They argued that "students who voluntarily participate in school athletics have reason to expect intrusions upon normal rights and privileges, including privacy (Jacobs, 2008)."
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9.

RATIONALE CONTINUED...

  • Lastly, "The governmental concern over the safety of minors under their supervision overrides the minimal, if any, intrusion in student-athletes' privacy ("Vernonia School District 47J v. Acton," n.d.)."
The judges felt that the need for students to be safe while playing sports at the school was worth the small invasion of privacy.
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10.

MAJORITY OPINION:

  • "Fourth Amendment rights, no less than First and Fourteenth Amendment rights, are different in public schools than elsewhere; the "reasonableness" inquiry cannot disregard the schools' custodial and tutelary responsibility for children"
The majority opinion that because of the duty of schools to create policies to keep students safe, it was not a violation of the Student Athlete's 4th amendment rights. The test is reasonable to conduct on students because it is not invasive and within the expectation of privacy for students in a public school system.
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11.

CONCURRING

  • "The effects of drug use disrupt the education of children for whom the State has undertaken a special responsibility of care and direction ("Vernonia School District 47J v. Acton," n.d.)."
The judges who concurred with the ruling believed that it was important for the schools to prevent drug use. They believe that drug use disrupts a students education. they further argued that "the Policy is directed only to student athletes, who suffer the increased risk that their drug use will cause them to injure themselves or other players during athletic competition ("Vernonia School District 47J v. Acton," n.d.)."
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12.

DISSENTING

  • "By the reasoning of today's decision, the millions of these students who participate in interscholastic sports, an overwhelming majority of whom have given school officials no reason whatsoever to suspect they use drugs at school, are open to an intrusive bodily search ("Vernonia School Dist. 47J v. Acton 515 U.S. 646 (1995)," n.d.)"
The dissenting judge felt that this ruling is unfair to the many student athletes that already are safe and not using drugs. This also opens up situations where administrators can search student athletes without evidence of drug use. They did agree that the ruling is justified because this is a blanket search instead of individualized search ("Vernonia School Dist. 47J v. Acton 515 U.S. 646 (1995)," n.d.).
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13.

IMPLICATIONS:

  • "More recently, the Court has ruled in favor of school policies requiring random drug testing for all extracurricular activities (Board of Education v. Earls, 2002)."
In 2002, the court used this case in their ruling of Board of Ed. of Independent School Dist. No. 92 of Pottawatomie Cty. v. Earls. This case furthered the idea that the school must have a identifiable drug problem before imposing a suspicion less drug-testing program a school ("Board of Ed. of Independent School Dist. No. 92 of Pottawatomie Cty. v. Earls," n.d.)."
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14.

DISPOSITION OF THE CASE:

  • One should not "dispose of a case by answering in isolation the question: Is there a compelling state interest here? Rather, the phrase describes an interest that appears important enough to justify the particular search at hand, in light of other factors that show the search to be relatively intrusive upon a genuine expectation of privacy ("Vernonia School Dist. 47J v. Acton 515 U.S. 646 (1995)," n.d.)."
The appeals court agrees that there needs to be an important enough reason for the particular search and should have searches performed if they are justified.
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15.

References:

Board of Ed. of Independent School Dist. No. 92 of Pottawatomie Cty. v. Earls. (n.d.). Retrieved from https://www.oyez.org/cases/2001/01-332
Jacobs, T. (2008, September 15). 10 Supreme Court Cases Every Teen Should Know. Retrieved from https://www.nytimes.com/learning/teachers/featured_articles/20080915monday....
Vernonia School Dist. 47J v. Acton 515 U.S. 646 (1995). (n.d.). Retrieved from https://supreme.justia.com/cases/federal/us/515/646/case.html
Vernonia School District 47J v. Acton. (n.d.). Retrieved from https://www.oyez.org/cases/1994/94-590

References
Board of Ed. of Independent School Dist. No. 92 of Pottawatomie Cty. v. Earls. (n.d.). Retrieved from https://www.oyez.org/cases/2001/01-332

Jacobs, T. (2008, September 15). 10 Supreme Court Cases Every Teen Should Know. Retrieved from https://www.nytimes.com/learning/teachers/featured_articles/20080915monday....

Vernonia School Dist. 47J v. Acton 515 U.S. 646 (1995). (n.d.). Retrieved from https://supreme.justia.com/cases/federal/us/515/646/case.html

Vernonia School District 47J v. Acton. (n.d.). Retrieved from https://www.oyez.org/cases/1994/94-590

Brian Gray