## Facts

- Alma Matos, a senior at Clinton High School, was enrolled in a journalism class taught by Marguerite Foley.
- The class used school-owned computers and printers, and Foley routinely reviewed student work created and printed on that equipment as part of class supervision.
- School policy prohibited students from using school computers for non-school-related purposes.
- During Foley’s class, Matos used a school computer to type a document containing offensive allegations about Foley and the school’s principal, including allegations that Foley and the principal were engaged in a sexual relationship.
- Matos printed the document on a school printer and placed the printout in her personal journal.
- Foley asked to see the printed document; Matos refused.
- Foley took the document and sent Matos to the principal’s office.
- The principal read the document and contacted Matos’s mother.
- The principal informed Matos and her mother that Matos would be suspended for ten days.
- Matos sued Foley, the principal, and the Clinton School District in federal district court, asserting federal constitutional claims (including procedural due process and Fourth Amendment claims) and seeking preliminary injunctive relief.
- Matos asked the court to order the school to expunge (or nullify) the suspension and to stop the district from disclosing the suspension to third parties, such as colleges, while the case was pending.

## Issues

1. Whether Matos showed a substantial likelihood of success on her claim that the ten-day suspension was imposed without the minimum procedures required by the Fourteenth Amendment for short-term school suspensions.
2. Whether Matos showed a substantial likelihood of success on her claim that Foley’s taking and reviewing the printed document constituted an unreasonable search or seizure under the Fourth Amendment in the public-school setting.
3. Whether Matos satisfied the requirements for preliminary injunctive relief (likelihood of success, irreparable harm, balance of hardships, and public interest) to justify expungement and nondisclosure orders before a final decision on the merits.

## Decision

- The court denied Matos’s motion for a preliminary injunction.
- The court concluded Matos did not make the required showing of a substantial likelihood of success on the merits of her federal claims.
- On due process, the court determined Matos likely received notice and an opportunity to respond consistent with the standards for short suspensions.
- On the Fourth Amendment claim, the court determined the teacher’s actions were likely reasonable under the school-search reasonableness standard given the school setting, school equipment, and the teacher’s supervisory role.
- Because likelihood of success was not shown, the court declined to order the suspension expunged or to bar the district from disclosing it while the case proceeded.

## Legal Principles

- A preliminary injunction requires a showing of: (1) substantial likelihood of success on the merits, (2) irreparable harm without relief, (3) a favorable balance of hardships, and (4) consistency with the public interest; likelihood of success is the most important factor.
- For short-term public-school suspensions, procedural due process generally requires notice of the charges, an explanation of the evidence, and an opportunity for the student to present her side; a full formal hearing is not required.
- In the school context, Fourth Amendment challenges to searches or seizures by school officials are evaluated for reasonableness: the action must be justified at its start and reasonably related in scope to the circumstances that prompted it.
- A student’s expectation of privacy is reduced for material created during class on school computers and printed on school printers, especially where school rules restrict non-school use and a teacher regularly reviews student output as part of instruction and supervision.
- A teacher may reasonably inspect and secure a document generated on school equipment during class when the student’s refusal to show it supports a reasonable suspicion that school rules are being violated or that the material is relevant to school discipline.

## Conclusion

The district court denied preliminary injunctive relief because Matos did not show a substantial likelihood of proving that the ten-day suspension violated federal constitutional requirements, and the court therefore declined to order expungement of the suspension or to restrict the school district’s handling or disclosure of the disciplinary record pending a final merits decision.


Matos by and through Matos v. Clinton School District, 350 F. Supp. 2d 303 (2003)