Is Strip Search in Schools Prohibited Under Fourth Amendment?


In the USA, school policies do not allow students to bring drugs to the institution without prior permission from the right authority. Over-the-counter drugs such as naproxen and ibuprofen are prohibited and learners should not possess them within the school environment. In order to ensure middle school students comply with the procedures, the administrators have the mandate to search for information that a student might be having the substances. However, despite the authority to perform such practices, educators must have reasonable suspicion. The paper explores whether the application of the strip search approach geared towards finding illegal drugs is banned under Fourth Amendment.

Safford Unified School District v. April Redding

The Safford Unified School District v. April Redding, 557 U.S. 364 (2009) was a court case that involved the Supreme Court USA in determining whether the strip search conducted against the student April Redding violated the Fourth Amendment of the U.S. Constitution. According to the incident, on October 8, 2003, a 13-year-old Savana Redding was subjected to a strip search by the assistant principal OF Safford Middle School, Arizona after following the accusation by another learner that Redding was distributing over-the-counter drugs to students. The court judges found that the intrusiveness did not meet reasonable suspicion.

Facts of the Case

Following the Safford Unified School District v. Redding, 557 U.S. 364 (2009) case, the assistant principal summoned Redding to his office. He then showed the student a planner containing several items which include knives, a cigarette, and a lighter. Furthermore, the administrator presented two types of drugs that is ibuprofen 400mg and naproxen 200-mg pills which the principal told Redding she was accused of distributing in the school despite the policies that prohibit such practices. In her response, Redding denied the allegations stating that she was not involved in such conduct.

When asked questions about the ownership of the planner, Redding admitted that it belonged to her but not the contents. This prompted the administrators to check her backpack where they found no drugs. To further confirm whether the student hid the substances under her inner garments, the assistant principal ordered her to be taken to the nurse for strip-searching. Upon arrival, she was asked to remove her bra and no pills were found. During the process, Redding’s private parts were exposed and visible to the people searching. Afterward, April Redding, Savana’s mother sued the administration citing that their actions violated the Fourth Amendment of the U.S Constitution.

New Jersey v. T.L.O

The New Jersey v. T.L.O., 469 U.S. 325(1985) is a renowned court decision made by the US Supreme Court addressing a case that involved a public high school student in possession of contraband substances. The case provided insight into the search of learners who are suspected of having illegal drugs. T.L.O was caught smoking which prompted the school officials to intrude on her purse where additional contraband such as marijuana and paraphernalia were found. T.L.O petitioned against the search citing that it violated her Fourth Amendment right (“New Jersey v. T.L.O.”, 2022). However, the Supreme Court ruled the intrusion was reasonable.

The Fourth Amendment

The Fourth Amendment of the U.S Constitution protects individuals from possible unreasonable searches and seizures. The practice must balance two interests whether it is deemed reasonable by the law. The equilibrium must exist between the intrusion on the person’s fourth Amendment Right and the government interest which include the safety of the public (Safford Unified School District, et al., v. April Redding, 2009). In Schools, the Fourth Amendment allows administrators to conduct searches on learners without having a search warrant. However, the law requires that for the act to happen, it has to be reasonable under all given conditions.

In the case of New Jersey v. T.L.O, the school administrators did not have strong ground to conduct searches against contraband items in school. However, after the court ruling, the school officials had a base ground for performing the search. The whole process relied on rationality which required the educators to determine whether the intrusion was allowed based on its scope. It further demands the officials examine whether the search was justified and able to produce evidence against the accused. The two criteria are critical in establishing the ground under which the middle school student can be searched.


Based on the Supreme Court decision on the case of Redding, the strip search she was subjected to violate her fourth Amendment Right. Therefore, such excessive intrusiveness is prohibited in Fourth Amendment. The court held that there are limits for searches and included a number of factors to be considered (“New Jersey v. T.L.O.”, 2022). “T.L.O directs school officials to limit the intrusiveness of a search, “in light of age and sex of the student and the nature of the infraction” 469 U.S., at 342.” This indicates that when performing a search of contraband items, the school officials must base their action on the age and sex of the accused student.

Generally, the Fourth Amendment provides necessary protection to people from searches and seizures. However, in the case of high school students in search of contraband items, educators have the mandate to perform the act under reasonable circumstances. For instance, in the case of Redding, the first attempt that involved searching backpack yielded a negative result (Safford Unified School District, et al., v. April Redding, 2009). Subjecting Redding to undressing exceeded the required limit based on her age and sex. Information from another student was not enough to raise reasonable suspicion. Furthermore, officials did not inform the student of her rights.

Following the Supreme Court decision on the case of New Jersey v. T.L.O, the validity of public middle school searches only requires ‘reasonable suspicion’ unlike the law enforcement unit that depends on probable cause. The Fourth Amendment requires evidence to facilitate the intrusion process. Considering the case of Redding, there was no evidence found yet the school officials continued with the excessive search of the undergarments. By stripping the student, the administrators violated the personal privacy that is guaranteed by the Fourth Amendment. Therefore, the approach does not meet the requirements of the Fourth Amendment.

Understanding Strip Search

A strip search refers to the process by which school officials engage in extreme intrusiveness following the nature of the reported infraction. The administrators may be forced to instruct the given student to remove the outer clothes upon searching. The process then exposes the learner’s private parts to the people conducting the pursuit. In most cases, the aim is to determine whether the victim concealed some of the contraband drugs in their undergarments. During the strip search, female students are required to shake their breasts and lift their pants. Similarly, male learners are made to raise their private parts.

Generally, conducting strip searches on public middle school students is improper. The Fourth Amendment requires school officials to examine all circumstances to determine the legitimacy and reasonableness of the intrusion. Failure to which, the act is considered a violation of personal rights. Administrators must consider a number of factors during the process which include scope, place, and manner in which the searching is performed. For instance, removing Redding’s bra to some extent exposed her breast implying how the operation was done violated her personal privacy.

Repercussions Associated with Strip Searches

Most students in middle schools are undergoing the adolescence stage. Their personal view is critical since they are in a sensitive phase of body development. Exposing their private body parts is detrimental to their wellbeing. For instance, Redding stated that during the strip search she hid her face to prevent the official from seeing her emotions (Safford Unified School District, et al., v. April Redding, 2009). The practice frightens the students, humiliates and lowers their self-esteem. It further interferes with their privacy and is against the individual’s Fourth Amendment Right provided by the U.S Constitution.

The practice of strip searches further causes serious effects on the development of victimized individuals. For instance, the student may start performing poorly in class work following the bad ordeal encountered. In case the student feels the accusation was false, the likelihood of developing a bad relationship with their educator increases. The mental and psychological torture associated with the practice can easily make the student quit schooling fearing the reoccurrence of a similar incident. The approach further facilitates their adolescent vulnerability especially for female learners at the age of 13 years and above.

The aspect of Crossing Professional Boundaries

In the event of strip-searching, there is the crossing of professional boundaries that affects the person’s privacy. For instance, while in school, the student is instructed to remove the undergarments exposing their private parts. The school officials especially in the case of Redding abused their power because they did not inform the learner of her rights. A thorough investigation is required to explore the underlying circumstance when determining the reasonable suspicion, however, the administrator does not undertake an effective investigation. The New Jersey v. T.LO decision provides that age is critical in the searching process but the strip intrusion does not consider that aspect.


Following the ‘Safford Unified School District, et al., v. April Redding”(2009) and New Jersey v. T.L.O., 469 U.S. 325(1985),’ the US Supreme Court established effective decisions that guide the application of the Fourth Amendment in schools. Based on the perspective of the Fourth Amendment, Strip search violates the individual’s Fourth Amendment Rights. The practice enhances the vulnerability of adolescents which affects their emotional development. Since stripping of students exposes their private parts, it, therefore, goes against the Fourth Amendment of the U.S. Constitution thus making it prohibited.


New Jersey v. T.L.O. United States Courts. (2022). Web.

Safford Unified School District, et al., v. April Redding, 479, 8 U.S. (2009). Web.

Cite this paper

Select style


LawBirdie. (2023, June 29). Is Strip Search in Schools Prohibited Under Fourth Amendment? Retrieved from


LawBirdie. (2023, June 29). Is Strip Search in Schools Prohibited Under Fourth Amendment?

Work Cited

"Is Strip Search in Schools Prohibited Under Fourth Amendment?" LawBirdie, 29 June 2023,


LawBirdie. (2023) 'Is Strip Search in Schools Prohibited Under Fourth Amendment'. 29 June.


LawBirdie. 2023. "Is Strip Search in Schools Prohibited Under Fourth Amendment?" June 29, 2023.

1. LawBirdie. "Is Strip Search in Schools Prohibited Under Fourth Amendment?" June 29, 2023.


LawBirdie. "Is Strip Search in Schools Prohibited Under Fourth Amendment?" June 29, 2023.