## Facts

- An Oklahoma public school district adopted a Student Activities Drug Testing Policy requiring middle and high school students to consent to urinalysis drug testing to participate in competitive extracurricular activities (including academic team, band, choir, cheerleading, and athletics).
- The policy required an initial test before participation, random tests during participation, and testing upon reasonable suspicion.
- Testing screened for illegal drugs and was not designed to disclose medical conditions or authorized prescription medications.
- Results were kept confidential; parents were notified of positive results; students were referred to counseling.
- The policy did not report results to law enforcement; sanctions were limited to exclusion from extracurricular activities for noncompliance or repeated positives.
- Students and parents sued under 42 U.S.C. § 1983, alleging the policy violated the Fourth Amendment.
- The district court upheld the policy; the court of appeals reversed, requiring a showing of a drug problem among the tested group.

## Issues

1. Whether suspicionless urinalysis testing of students participating in competitive extracurricular activities is an unreasonable search under the Fourth Amendment.
2. Whether a school must show an identifiable drug problem among the specific subgroup tested before implementing suspicionless testing.

## Decision

- The Supreme Court reversed the court of appeals and upheld the policy in a 5–4 decision.
- The Court held that the urinalysis program was a search but reasonable under the Fourth Amendment in the public-school “special needs” context.
- The Court rejected a constitutional requirement that the school demonstrate a threshold level of drug abuse among the particular extracurricular group tested.
- The Court concluded the policy reasonably furthered the school district’s interest in preventing and deterring student drug use.

## Legal Principles

- Collection and testing of urine by a public school constitutes a Fourth Amendment search.
- In public schools, searches may be evaluated for overall reasonableness under a special-needs framework rather than warrant and probable-cause requirements.
- Reasonableness is assessed by balancing: (1) the student’s privacy interest, (2) the character and intrusiveness of the search, and (3) the nature and immediacy of the governmental concern and the efficacy of the program.
- Students who voluntarily participate in regulated extracurricular activities have a reduced expectation of privacy compared to the general student body.
- Confidential, non-law-enforcement drug testing with limited school-based consequences may be treated as minimally intrusive for Fourth Amendment purposes.
- A school may adopt preventive measures to deter drug use without proving a severe or pervasive drug problem within the targeted subgroup.

## Conclusion

The Court held that a public school district may require suspicionless urinalysis drug testing as a condition of participating in competitive extracurricular activities because, under special-needs balancing, the program is a reasonable search aimed at deterring and detecting student drug use.


Bd. of Educ. of Indep. Sch. Dist. No. 92 of Pottawatomie Cnty. v. Earls, 536 U.S. 822 (2002)