## Facts

- A 13-year-old eighth-grade student was taken from class to the assistant principal’s office after a report that she was distributing pills at school.
- The assistant principal confronted her with a day planner containing contraband items; she admitted ownership but said she had lent it to a friend and denied the items were hers.
- School officials possessed pills identified as prescription-strength ibuprofen (400 mg) and over-the-counter naproxen, both prohibited at school without prior permission.
- The student denied possessing or distributing pills and agreed to a search of her backpack and outer clothing; no pills were found.
- The assistant principal directed a further search in the nurse’s office, where female school staff required the student to remove outer clothing and to pull out and shake her bra and pull out the elastic of her underpants, exposing private areas to some degree; no pills were found.
- The student and her mother brought a 42 U.S.C. § 1983 action alleging an unreasonable search in violation of the Fourth Amendment.

## Issues

1. Whether the underwear search of a 13-year-old student, conducted to find suspected pills prohibited by school policy, was unreasonable under the Fourth Amendment standard governing public school searches.
2. Whether the individual school officials were personally liable for damages under § 1983 or were protected by qualified immunity.

## Decision

- The Court held the underwear search violated the Fourth Amendment because its scope was excessively intrusive relative to the suspicion and the suspected infraction.
- The Court held the individual officials were entitled to qualified immunity because existing precedent in 2003 did not clearly establish that this specific search was unconstitutional.
- The Court left questions regarding potential school district liability for further proceedings on remand.

## Legal Principles

- Public school searches are judged by Fourth Amendment reasonableness, not probable cause.
- A school search is permissible when it is reasonably related to the search objectives and not excessively intrusive in light of the student’s age and sex and the nature of the suspected infraction.
- A search reaching a student’s underwear is a distinct level of intrusion and requires specific justification matching that intrusion, including reason to suspect contraband is likely hidden there and, when relevant, that the suspected item poses a meaningful danger.
- Qualified immunity shields officials from damages when the unlawfulness of their conduct was not clearly established at the time, such that they lacked fair notice their actions violated the Constitution.

## Conclusion

The Court ruled that the strip search of a 13-year-old for suspected ibuprofen and naproxen was an unreasonable school search under the Fourth Amendment, but it denied damages against the individual officials because the law at the time did not clearly prohibit the specific conduct.


Safford Unified Sch. Dist. No. 1 v. Redding, 557 U.S. 364 (2009)