## Facts

- Goshen County School District No. 1 adopted a written policy requiring random, suspicionless drug and alcohol testing for students in grades 7–12 who chose to participate in any school-sponsored extracurricular activity.
- The district adopted the policy after surveying students and concluding that student drug and alcohol use was a significant problem.
- Participation in extracurricular activities was voluntary, and consent to testing was a condition of participation rather than a condition of school attendance.
- Students were selected for testing through a neutral random process.
- The policy limited consequences of a positive test to extracurricular participation (e.g., suspension from activities) and referral for assistance; it did not impose expulsion or criminal referral.
- Test results were kept confidential and were not to be used by law enforcement.
- A coalition of parents and students sued for declaratory and injunctive relief, alleging violations of the Fourth Amendment and the Wyoming Constitution, including Article 1, § 4.

## Issues

1. Whether random, suspicionless drug and alcohol testing of students who participate in extracurricular activities is an unreasonable search under the Fourth Amendment.
2. Whether Article 1, § 4 of the Wyoming Constitution provides greater protection than the Fourth Amendment in this context, rendering the policy unconstitutional under state law.

## Decision

- The Wyoming Supreme Court affirmed summary judgment for the school district.
- The court held the policy was reasonable under the Fourth Amendment under the school “special needs” doctrine.
- The court held Article 1, § 4 of the Wyoming Constitution did not provide broader protection than the Fourth Amendment for this type of school drug-testing policy.
- The policy was upheld as constitutional under both federal and state search-and-seizure provisions.

## Legal Principles

- Student drug testing is a “search,” but in public schools it may be reasonable without individualized suspicion when “special needs” beyond ordinary law enforcement are present.
- Reasonableness is determined by balancing (1) students’ privacy expectations, (2) the character and scope of the intrusion, and (3) the governmental interests served.
- Students have reduced privacy expectations in school; students who voluntarily participate in extracurricular activities have further reduced expectations due to added eligibility rules and conditions.
- A testing program is more likely to be reasonable when procedures minimize intrusiveness, results are kept confidential, and consequences are limited to school-related, noncriminal measures.
- Wyoming courts may interpret the state constitution independently, but where Article 1, § 4 is treated as coextensive with the Fourth Amendment in the relevant setting, the same balancing framework may apply.

## Conclusion

The Wyoming Supreme Court upheld a school district’s random, suspicionless drug and alcohol testing requirement for voluntary extracurricular participants, concluding that the program was a reasonable school search under the Fourth Amendment and that Wyoming’s Article 1, § 4 did not require a different result.


Hageman v. Goshen Cnty. Sch. Dist. No. 1, 256 P.3d 487 (Wyo. 2011)