## Facts

- A rural Missouri school district (about 225 students) learned on October 26, 1993, that bus seats had been freshly cut, raising concern that a knife or similar weapon was on campus.
- During the response, students reported that a gun was at school that morning.
- The principal and a teacher conducted a search of all male students in grades 6–12 by bringing classes to a classroom.
- Students removed jackets, shoes, and socks; emptied pockets; and placed items on tables.
- Officials used a metal detector; pat-downs occurred when the detector sounded; coats were patted and objects felt in coat pockets were removed.
- Ninth-grader Ramone Lea was searched despite no individualized suspicion he had damaged the bus or brought a weapon.
- In Lea’s coat, a matchbox containing a white substance was found and later identified as crack cocaine.
- After a disciplinary hearing, Lea was expelled for the rest of the school year for possession of crack cocaine.
- Lea’s guardian sued under 42 U.S.C. § 1983 alleging a Fourth Amendment violation from the search and a due process violation in the expulsion process.

## Issues

1. Whether the Fourth Amendment exclusionary rule applies to school disciplinary hearings, requiring suppression of evidence obtained through an unconstitutional search by school officials.
2. Whether a suspicionless, schoolwide search of students (including Lea’s coat pocket) was reasonable under the Fourth Amendment given reports of weapons on campus.

## Decision

- The Eighth Circuit reversed the judgment for Lea.
- The court held the Fourth Amendment exclusionary rule does not apply to school disciplinary hearings.
- The court held the search of Lea’s coat pocket was constitutionally reasonable under the Fourth Amendment.
- Because there was no Fourth Amendment violation, the damages award and liability determination against the district and officials were improper.

## Legal Principles

- The exclusionary rule is a judicially created, deterrence-based doctrine whose application depends on whether deterrent benefits outweigh social costs; it is not automatically extended to noncriminal school disciplinary proceedings.
- Evidence obtained by school officials is not subject to suppression in school discipline hearings under the Fourth Amendment exclusionary rule.
- Student searches by school officials are judged by reasonableness: a search must be justified at its inception and reasonable in scope relative to the objectives and the student’s privacy interests.
- Where school officials confront credible, immediate safety concerns involving weapons, a minimally intrusive, non-individualized sweep may be reasonable even without individualized suspicion.
- If a weapons-oriented search is lawful in inception and scope, discovery and seizure of other contraband found during that search is not invalid solely because the contraband is unrelated to the original objective.

## Conclusion

The court rejected suppression as a remedy in school expulsion proceedings and upheld a suspicionless, safety-driven search of students as reasonable, reversing § 1983 liability and damages predicated on treating the expulsion as “wrongful” due to allegedly unconstitutional evidence.


Thompson v. Carthage Sch. Dist., 87 F.3d 979 (8th Cir. 1996)