Safford Unified School District v. Redding | |
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Argued April 21, 2009 Decided June 25, 2009 | |
Full case name | Safford Unified School District #1, et al. v. April Redding |
Docket no. | 08-479 |
Citations | 557 U.S. 364 (more) 129 S. Ct. 2633; 174 L. Ed. 2d 354; 77 U.S.L.W. 4591; 245 Ed. Law Rep. 626; 09 Cal. Daily Op. Serv. 7974; 2009 Daily Journal D.A.R. 9383; 21 Fla. L. Weekly Fed. S 1011 |
Argument | Oral argument |
Opinion announcement | Opinion announcement |
Case history | |
Prior | Summary judgment affirmed, 504 F.3d 828 (9th Cir. 2007); rehearing en banc granted, 514 F.3d 1383 (2008); reversed, 531 F.3d 1071 (9th Cir. 2008); cert. granted, 555 U.S. 1130 (2009). |
Holding | |
(1) The search of Redding's underwear violated the Fourth Amendment. (2) Petitioners are protected from liability by qualified immunity. (3) The issue of the school district's liability should be addressed on remand. | |
Court membership | |
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Case opinions | |
Majority | Souter, joined by Roberts, Scalia, Kennedy, Breyer, Alito; Stevens, Ginsburg (Parts I–III) |
Concur/dissent | Stevens, joined by Ginsburg |
Concur/dissent | Ginsburg |
Concur/dissent | Thomas |
Laws applied | |
U.S. Const. amend. IV |
Safford Unified School District v. Redding, 557 U.S. 364 (2009), was a case in which the Supreme Court of the United States held that a strip search of a middle school student by school officials violated the Fourth Amendment to the U.S. Constitution, which prohibits unreasonable searches and seizures.
On October 8, 2003, the assistant principal of Safford Middle School in Safford, Arizona, informed 13-year-old Savana Redding that another student had accused her of distributing prescription-strength ibuprofen, which was disallowed without prior permission by school rules. Redding denied this accusation, and after a search of her belongings did not reveal any pills, school officials instructed her to remove her outer clothing and pull out her bra and underpants, which also did not reveal any pills.
Redding's mother sued the Safford Unified School District and the school officials who searched her daughter, arguing that they had violated the Fourth Amendment. The district court granted summary judgment in favor of the school officials on the basis that they were entitled to qualified immunity. With the help of the American Civil Liberties Union, Redding appealed to the U.S. Court of Appeals for the Ninth Circuit, which reversed the district court, holding in an en banc session that the search violated the Fourth Amendment and that the assistant principal was not entitled to qualified immunity because he violated clearly established law at the time of the search.
On June 25, 2009, the Supreme Court affirmed in part, reversed in part, and remanded. In an 8–1 decision authored by Justice David Souter,[a] the Court found that the search failed to meet the "reasonable suspicion" standard for searches of students in a school setting established by the Court in New Jersey v. T. L. O. (1985), stating that the school lacked reasons to suspect either that the drugs presented a danger or that they were concealed in her underwear. However, the Court also found that because there was sufficient doubt as to whether the law was clearly established at the time of the search, the school officials were entitled to qualified immunity. Finally, the Court stated that its conclusions do not resolve the school district's liability and remanded the case for lower courts to consider that issue.
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