## Facts

- Wahkiakum School District perceived ongoing student drug and alcohol problems and adopted multiple prevention measures beginning in 1994.
- After continued concerns and survey data indicating substantial student drug and alcohol use, the district adopted Policy No. 3515.
- The policy required all interscholastic student athletes to submit to random urinalysis drug testing as a condition of participation.
- Positive test results were not reported to law enforcement; consequences were tied to athletic participation rather than school suspension.
- Student athletes Aaron and Abraham York and Tristan Schneider participated in sports, signed required consent forms, and were tested.
- Their parents sued, alleging the policy disturbed students’ private affairs without authority of law in violation of article I, section 7 of the Washington Constitution.
- The trial court upheld the policy, and the Washington Supreme Court granted direct review.

## Issues

1. Whether a public school district’s warrantless, random, suspicionless urinalysis drug testing of student athletes violates article I, section 7 of the Washington Constitution.
2. Whether article I, section 7 permits a “special needs” exception allowing suspicionless searches based on interest balancing.

## Decision

- The Washington Supreme Court reversed the judgment upholding the policy.
- The court held that random and suspicionless urinalysis drug testing of student athletes is a disturbance of private affairs under article I, section 7.
- Because the testing was warrantless and not justified by a recognized exception, it lacked the required authority of law.
- The court declined to recognize a “special needs” exception under article I, section 7 to authorize the testing program.
- The policy was unconstitutional under article I, section 7.

## Legal Principles

- Article I, section 7 asks whether the government has disturbed a person’s private affairs without authority of law, not whether a search is reasonable under open-ended balancing.
- Urinalysis drug testing is a search that intrudes on bodily privacy and implicates private affairs.
- Authority of law generally requires a warrant or a narrow, established exception; broad new exceptions are disfavored.
- General deterrence, health, and safety objectives—standing alone—do not supply authority of law for warrantless, suspicionless searches.
- A student’s signed consent to participate in athletics does not necessarily constitute voluntary consent sufficient to waive article I, section 7 protections when participation is conditioned on submitting to invasive testing.

## Conclusion

Washington’s privacy clause prohibits public schools from requiring random, suspicionless urinalysis drug testing of student athletes absent a warrant or a recognized, narrow exception, and the court refused to import a federal-style “special needs” balancing exception into article I, section 7.


York v. Wahkiakum Sch. Dist. No. 200, 163 Wash. 2d 297, 178 P.3d 995 (2008)