Vernonia School District v. Acton (47J)

In deciding this case, the Court noted the special status of students, who are voluntarily put under the authority of school personnel by their parents. As such, school officials function as de facto parents while students are in their charge, and there are no constitutional guidelines for nonviolent parental discipline of children to ensure order. The Court also observed that athletes engaged in team sports understand that they must voluntarily give up some rights to privacy, given the communal nature of locker room facilities and team activities in general. Thus, in the Court's view, students in general, and student athletes in particular, may expect their activities to be subject to more scrutiny and have their behavior more circumscribed by school authorities than other individuals. As such, the Court ruled that Vernonia's policy did not violate the constitutional rights of students, and remanded the case to the court of appeals for reconsideration.

The legal justification for this ruling was quite straightforward. Random drug testing of railroad employees had been deemed constitutional by the Court in Skinner v. Railway Labor Executives' Assn. (1989), given the state's compelling interest in maintaining passenger safety by insuring that transportation employees are not working while under the influence of intoxicants. Furthermore, the Court held in Delaware v. Prouse (1979), that a particular search's validity under the Fourth Amendment "is judged by its intrusion on the individual's Fourth Amendment interests against its promotion of legitimate governmental interests." In this case the Court judged that the state's interest in discouraging drug abuse among students and maintaining order within the classroom was so compelling as to justify some abridgement of student's Fourth Amendment rights. With regard to Fourteenth Amendment prohibitions against invasion of privacy, the Court ruled that, given the relative lack of privacy accepted by all participants in team sports, the additional intrusion represented by urinalysis was negligible. At any rate, the Court had already established in New Jersey v. T.L.O. (1985), that "students within the school environment have a lesser expectation of privacy than members of the population generally." Therefore the policy was deemed reasonable and acceptable under the Fourteenth Amendment.