## Facts

- Aaron M. Ogletree was a student at Cleveland State University (CSU), a public university treated as an arm of the State of Ohio.
- CSU offered online courses and permitted instructors to use remote proctoring measures to deter cheating, including requiring a webcam “room scan” before certain remote exams.
- In an online chemistry course, a remote exam proctor required students to perform a pre-exam room scan using their webcams.
- Ogletree took the exam from his bedroom and told the proctor that personal financial and tax-related documents were visible and that he was concerned about displaying them on camera.
- The proctor required compliance as a condition of taking the exam, and Ogletree panned his laptop camera around his bedroom, briefly exposing private areas and documents.
- Ogletree asserted he had limited practical alternatives to remote testing during the pandemic and challenged the room-scan requirement as a violation of the Fourth Amendment.
- Ogletree sued under 42 U.S.C. § 1983; the parties filed cross-motions for summary judgment on a largely undisputed record.

## Issues

1. Whether a university-mandated pre-exam webcam “room scan” of a student’s bedroom constitutes a Fourth Amendment “search.”
2. If it is a search, whether the room scan is reasonable under the Fourth Amendment given the university’s interest in academic integrity and the circumstances of remote testing.
3. Whether the plaintiff was entitled to summary judgment and appropriate equitable relief based on the Fourth Amendment violation.

## Decision

- The court granted Ogletree’s motion for summary judgment and denied CSU’s motion.
- The court held the mandatory room scan of Ogletree’s bedroom constituted a Fourth Amendment search.
- The court held the search was unreasonable on the record presented because it intruded into the home without sufficient justification or tailoring to the asserted anti-cheating interest.
- The court entered judgment for Ogletree on liability and addressed the request for permanent injunctive relief in its amended order and related rulings.

## Legal Principles

- A government-directed visual inspection of a home—conducted through compelled webcam panning—can constitute a Fourth Amendment search because it intrudes on a reasonable expectation of privacy in the home.
- The home receives the highest Fourth Amendment protection; compelled exposure of private living space is not treated as mere observation of what is already in public view.
- “Plain view” concepts do not apply where the individual must manipulate technology to reveal areas not otherwise visible to the state.
- Disclosures are not “voluntary” for Fourth Amendment purposes when required as a condition to access a public benefit (here, taking a required remote exam).
- In assessing reasonableness for a warrantless, suspicionless search tied to administrative objectives, courts balance the privacy intrusion against the governmental interest and consider tailoring, necessity, and less intrusive alternatives.
- A university’s interest in academic integrity can be legitimate, but a scan into a student’s bedroom may be unreasonable when highly intrusive and not shown to be sufficiently necessary or effective compared to available alternatives.

## Conclusion

The court held that CSU’s mandatory remote-exam webcam room scan of a student’s bedroom was a Fourth Amendment search and, on the undisputed record, an unreasonable intrusion into the home; it granted summary judgment to the student and denied the university’s cross-motion while addressing equitable relief.


Ogletree v. Cleveland State Univ., 2022 WL 17826730 (N.D. Ohio Dec. 20, 2022)