## Facts

- Highland, Indiana school officials planned an unannounced, school-wide drug inspection during the 1978–79 school year due to concern about student drug use.
- On March 23, 1979, school administrators and police conducted inspections at the junior and senior high schools during first period.
- Drug-detecting dogs were walked through classrooms while students remained at their desks; the dogs were used to detect the odor of marijuana.
- If a dog alerted on a student, the student was directed to empty pockets and/or a purse.
- In eleven instances, including Diane Doe’s, dogs continued to alert after the student complied; those students were taken for a more intrusive search.
- Doe, a junior high student, was taken to the nurse’s station and, in the presence of two women, was required to remove her clothing for a nude (strip) search; no drugs were found.
- The overall operation resulted in drugs being found on seventeen students, but not on Doe.
- Doe sued under 42 U.S.C. §§ 1983 and 1985, alleging constitutional violations and seeking damages and injunctive relief; the litigation ultimately proceeded only as to Doe and Highland-related defendants.

## Issues

1. Whether the school-wide use of drug-sniffing dogs in classrooms, and the ensuing pocket/purse-emptying searches after an alert, constituted unreasonable searches or seizures under the Fourth Amendment.
2. Whether a nude (strip) search of a student, based solely on a dog’s alert and without additional individualized facts, violated the Fourth Amendment.
3. Whether damages or injunctive relief were available against school and police defendants, including defendants who did not personally participate in the strip search.

## Decision

- The court upheld the school-wide canine sweep and the limited follow-up measures requiring students to empty pockets or purses after a dog alert.
- The court held that Doe’s nude (strip) search, conducted solely because a dog alerted to her, was unreasonable and violated the Fourth Amendment.
- The court declined to award money damages, finding the responsible school administrators acted in good faith.
- The court granted summary judgment for certain defendants (including the police chief and dog trainer) who did not personally participate in the unconstitutional strip search decision.

## Legal Principles

- Fourth Amendment analysis in public schools balances students’ privacy interests against the school’s custodial and disciplinary responsibility to protect student welfare and maintain order.
- Students have a reduced expectation of privacy in the school environment, which can make minimally intrusive detection techniques and limited searches reasonable when tied to drug-control objectives.
- Canine sniffs in a school-wide inspection, and limited searches such as emptying pockets or purses following a dog alert, may be reasonable given the governmental interest in deterring and detecting drugs.
- Strip searches are highly intrusive and require strong, individualized justification; a dog alert alone is insufficient to justify a nude search of a student.
- Personal involvement matters for liability under § 1983; defendants not participating in, directing, or causing the unconstitutional search are not liable on that claim.
- Good-faith conduct by school officials may bar or limit monetary damages even when a constitutional violation is found.

## Conclusion

The court upheld a school-wide drug-dog sweep and limited, alert-based pocket or purse searches as reasonable in the public-school setting, but ruled that a student strip search based only on a dog’s alert violated the Fourth Amendment and did not support damages where administrators acted in good faith and other defendants lacked personal involvement.


Doe v. Renfrow, 475 F. Supp. 1012 (N.D. Ind. 1979)