Vernonia School District v. Wayne Acton, 515 U.S. 646 (1995)

In the late 1980s, the Vernonia (Oregon) School District perceived an increase in drug and alcohol use among its students and quickly took measures to address the problem. The district implemented drug education classes and used drug-sniffing canines to help detect the presence of drugs on school campuses. Acting on the administrators’ claim that student athletes were heavily involved in the drug culture, the district held a parent meeting to discuss a new drug policy that would require athletes to submit to a urine analysis at the beginning of every sport season. The proposal also required an additional submission, once a week, by 10 percent of the athletes chosen at random. In addition, athletes would be required to provide a doctor’s authorization for any medication they were taking at the time of a drug exam. To maintain personal privacy, the urine samples of male athletes would be collected while they were fully clothed, with back turned, and at a distance of 12 to 15 feet from a monitor of the same sex. Female athletes produced their samples inside an enclosed bathroom stall while being monitored audibly by a person of the same sex from outside the stall. The sample would then be sent to a laboratory and analyzed for the presence of marijuana, amphetamines, and cocaine. The parents unanimously agreed to the new policy.
In the fall of 1991, the respondent, James Acton, was denied the right to play football because he and his parents refused to sign the new policy’s consent forms. An action was filed against the district claiming that the policy violated the Fourth and Fourteenth Amendment protection against unreasonable searches and seizures. The district court quickly struck down the claim. Upon appeal, the Ninth Circuit reversed the district court’s decision, holding that the policy was, in fact, a breach of Fourth and Fourteenth Amendment protection from searches and seizures without due process.
The United States Supreme Court granted a hearing of this case under a writ of certiorari. The Court argued that the protection given by the Fourth Amendment, and ratified to the states through the Fourteenth Amendment, is only given for searches and seizures that are unreasonable. To determine whether a particular search is unreasonable, the Court must balance the extent of Fourth Amendment intrusion against society’s benefit or need. Typically, probable cause is required to establish the reasonableness of a particular search. However, under certain circumstances, the Court has allowed searches to be conducted without probable cause if the circumstances were exigent or special in nature.
The Court held that the interests of public schools exist in an area of law where the special needs of the school outweigh the need for probable cause before conducting searches. The Court has long held that because public schools have been given the temporary custody of children, they have also been given the responsibility and authority to protect the well-being of those children. In normal circumstances the submission of urine analyses would be deemed unconstitutional if requested at random and without any probable cause. However, schools have the authority to require rules of conduct and to maintain a degree of control that would not be allowed in normal circumstances.
The Court decided that the expectation of privacy is naturally diminished when athletes choose to participate in a sport. Locker and dressing room activities, as well as preseason physical exams, automatically reduce athletes’ reasonable expectation of privacy. Because the submission of a drug sample is conducted in such a way as to limit the further intrusion of privacy, the policy was an acceptable means to the ultimate intention of the district’s policy. The Court viewed the submission of samples by both male and female athletes as nearly identical to the conditions that students are exposed to every day while using the public restrooms. Therefore, the way in which the submissions were conducted was not unreasonable and did not violate the students’ Fourth Amendment rights.
The Court also found that requiring the proof of medical authorization for the use of prescription drugs was, likewise, not a violation of the students’ Fourth Amendment rights. The policy did permit student athletes to provide the required information directly to the laboratory in a sealed envelope, thus maintaining the same standard of medical privacy that the student is provided under everyday protection.
In this case the Court balanced the randomness of the searches, the intrusiveness of the searches, and the expectation of medical privacy against the district’s need to halt a rising drug epidemic and decided that the policy only slightly intruded on the students’ rights under the Fourth Amendment. The Court ruled that the policy’s slight intrusion into the privacy of athletes was greatly outweighed by the need for the district to ensure the safety of students.