Sample Case Study on T.L.O. vs New Jersey Case

T.L.O. vs New Jersey Case

Facts of the Case

T.L.O. was a 14-year-old schoolgirl at New Jersey High School. Together with her friend she was found by her teacher while smoking cigarettes. The teacher considered that a violation of school rules and took the two students to an administrator, who handled them. T.L.O. denied the allegations while the second student confessed to smoking cigarettes. T.L.O. was accused by the administrator of being dishonest to him and decided to check her purse to find the cigarettes. When the administrator checked her purse, he found rolling paper and a packet of cigarettes among other things (United States Courts, 2016). The administrator suspected T.L.O., because he was aware that cigarette-rolling paper was used for smoking marijuana. He continued to search through T.L.O.’s handbag and discovered a tiny plastic bag that had a glass-like substance, and other things that looked like drug related items together with a wad of money, pipe, and a list of students who owed T.L.O. money, and a letter that seemed to implicate T.L.O.

The administrator contacted the police, and the police contacted T.L.O.’s mother. When she was taken to the police by her mother, she confessed that she was selling marijuana. T.L.O was charged in a Juvenile Court because of her age. The court failed to give her a chance to keep out her confession and the proof from the search. Her lawyer was of the view that searching her purse was an abuse of the Fourth Amendment. T.L.O. was sentenced to one-year trial.

According to the Fourth Amendment, individuals have a right to be protected in their persons, papers, houses, and effects from unreasonable seizures and searches. Additionally, it provides that their rights shall not be violated and no arrest warrants shall be issued except upon probable cause, supported by affirmation or oath, and especially describing the place where the search is to be conducted, and the individuals or things to be seized (United States Courts, 2016). A number of court decisions have been delivered on the Fourth Amendment.


            The first decision was made by a lower court 1: Juvenile and Domestic Relations Court of Middlesex County, N.J (United States Courts, 2016). In its ruling, the court held that the Fourth Amendment is applicable to searches conducted by school officials; however, a school official may carry out a search of a student’s person under particular settings. In particular, the Juvenile Court ruled that school officials might search a student, if they suspect that a crime has been committed or is being committed, or they have sound reasons to believe that the search is required to maintain school discipline or enforce school policies. Applying the mentioned standards to the facts of the present case, it was the court’s view that the Fourth Amendment was never violated by the school administrator’s search. Consequently, the court found T.L.O. delinquent and sentenced to one-year probation.

On appeal, the case was heard by the Appellate Division (New Jersey State Court System) (United States Courts, 2016). This court affirmed the ruling of the Juvenile court indicating that the Fourth Amendment was not violated. However, it vacated the earlier delinquency adjudication, referred back the case to the Juvenile Court for a decision to be made on whether T.L.O. had intentionally and voluntarily relinquished her Fifth Amendment right against self-incrimination prior to confessing (United States Courts, 2016).

The case was appealed to the New Jersey State Supreme Court (the third lower court to hear this case). In its ruling, the court concurred with the decision of the lower courts that the Fourth Amendment applies to the conduct of school officials. It also supported the argument that school officials may undertake a warrantless search of a student, if they have a reason to believe that the said student has evidence of illegal activity or activity that can negatively affect school order and discipline. Nonetheless, the highest court in New Jersey eventually reversed the earlier ruling. It held that in T.L.O.’s case, the conduct of the school administrator was unreasonable since merely possessing cigarettes is not a violation of school rules. The school official’s desire to catch T.L.O. in a lie was not sufficient justification to rummage through her purse.

Finally, the issue found its way to the U.S. Supreme Court. The court was required to determine whether evidence that a school administrator unlawfully seizes, without the involvement of law enforcement officers, can be permissible as evidence at juvenile delinquency proceedings. In its ruling, the Supreme Court did not handle the issue. The Court concluded that, under the conditions of the case, the school official’s move to search T.L.O.’s purse was not a violation of the Fourth Amendment of the American constitution (United States Courts, 2016). Although the Court failed to make a ruling on whether evidence seized illegally should be suppressed in a juvenile delinquency hearing, it held that the Fourth Amendment is applicable to school administrators. The Court voted in favor 6 to 3. The parties argued the case on 28 March 1984 and reargued on 2 October 1984. Eventually, the court delivered its decision on 15 January 1985. The majority judgment was read by Justice White.

The Supreme Court reached the conclusion that the ban on unreasonable searches and seizures under the Fourth Amendment is not limited to actions of law enforcement officers. It also applies to the conduct of school administrators. Teachers in public schools serve as agents of the state, and not merely agents of the parents. Consequently, their actions are governed by the Fourth Amendment. Additionally, the Court maintained that students have an authentic expectation of privacy when in school. Nonetheless, their expectation of privacy must be counterbalanced against the demands of the school authorities to maintain a good educational environment. Thus, school administrators require no warrant and neither do they need a probable cause that a crime has happened before they can conduct a search on a student. Instead, under all situations, reasonableness of search determines its legality.

My well-vetted opinion was that the ruling of the Lower and Supreme Court was final and I concur with it, because the Fourth Amendment is not restricted to actions of law enforcement authority. The administrator was right to search T.L.O.’s purse, because he suspected that there was something wrong going on in the school compound.

Summary of the Case

A teacher in a New Jersey high school found two girls smoking cigarettes in the bathroom and reported them to the principal. T.L.O. denied the accusations while the other girl confessed. The Principal decided to check the purse of the girl to find proof that they were selling marijuana in school. When T.L.O. was taken to the police station, she admitted that she was selling marijuana (United States Courts, 2016). Her lawyer argued that the school administrator dishonored the Fourth Amendment. The lower Court sided with the school. Then T.L.O. decided to take the case to the New Jersey Supreme Court that indicated it was unreasonable for the principal to search through her purse and the evidence found could not be used. This decision was later appealed in the United States Supreme Court. The justices in the Supreme Court in N.J ruled that the school administrator had dishonored T.L.O’s Fourth Amendment rights (United States Courts, 2016). The high court ruled that the school administrators must not have a probable cause or search warrant to carry out a search, because students have a reduced prospect of privacy while in school. The case was taken to the Supreme Court of the U.S that ruled that the school had not dishonored the Fourth Amendment. The main argument was that primary and secondary schools should not be given similar level of search and seizure protection like juveniles and adults in non-school settings. Because T.L.O was 14 years, she faced law-breaking charges in a juvenile court. She was found delinquent and was put on 12 months’ probation. After a prolonged appeal process in the New Jersey judicial system, the U.S. Supreme Court made a decision to hear the case.

I would rule in favor of the school, because if a student is found violating the school rules, it is the responsibility of school administrators to take action against them. Secondly, the school administrators would not have violated the Fourth Amendment. Thirdly, a student of T.L.O.’s age would pose great danger in the future, because she is already aware of the business of selling marijuana. Consequently, some measures must be put in place to control the situation.



United States Courts (2016). New Jersey v. T.L.O Retrieved 23 December 2016, from