## Facts

- Madison High School officials faced escalating gun-related incidents on or near campus in fall 1990, including verified firearm presence and threats prompting a student transfer for safety.
- The weekend before the search, students reported being fired at after a basketball game, and gunshots were heard after a school dance; spent casings were recovered and crowd reaction confirmed firearms.
- By Monday, November 19, 1990, rumors of a possible school “shootout” heightened concern about imminent harm to students and staff.
- The school system’s published policy stated lockers were school property, subject to inspection as necessary; the school retained master keys, prohibited private locks, and provided notice to students and parents.
- School security personnel conducted random locker inspections; in the locker assigned to Isiah B., they found a firearm and cocaine in a coat pocket.
- A delinquency petition alleged possession of a firearm on school grounds and possession of cocaine with intent to deliver; the circuit court denied suppression and adjudicated Isiah delinquent.

## Issues

1. Whether a random search of a student’s school locker, conducted by school authorities in response to escalating gun incidents and an imminent threat of harm, violated the Fourth Amendment or Article I, § 11 of the Wisconsin Constitution.
2. Whether the school’s ownership-and-inspection policy eliminated or substantially reduced a student’s reasonable expectation of privacy in an assigned locker.
3. Whether the search was reasonable in its justification and scope under school-search standards.

## Decision

- The Wisconsin Supreme Court affirmed the denial of the suppression motion and the delinquency adjudication.
- The court held the random locker search was constitutionally permissible under both the federal and state constitutions given the documented, immediate safety threat.
- The court relied on the school’s retained control over lockers and clear notice of inspection authority to find any student privacy interest in lockers significantly diminished.
- The court found the search reasonable at its inception (credible risk of imminent serious harm) and reasonable in scope (limited to lockers and conducted as a school safety measure rather than general law enforcement).

## Legal Principles

- School searches are evaluated under a reasonableness standard that accounts for the school setting and the government’s interest in student and staff safety, rather than traditional warrant and probable-cause requirements.
- A student’s expectation of privacy in a school locker is reduced when the locker is school property, the school retains access and control (e.g., master keys and no private locks), and students and parents receive notice of inspection rights.
- Suspicionless (random) locker searches may be reasonable when supported by specific, credible facts showing an imminent risk of serious harm and when the method is appropriately limited to the safety objective.

## Conclusion

The court upheld a random school locker search conducted during an acute campus safety crisis, concluding that the school’s compelling interest in preventing imminent gun violence outweighed the reduced privacy interest students held in lockers subject to an explicit inspection policy.


In re Interest of Isiah B., 176 Wis. 2d 639, 500 N.W.2d 637 (Wis. 1993)