Board of Education v. Earls

{{Infobox SCOTUS case

|Litigants=Board of Education v. Earls

|ArgueDate=March 19

|ArgueYear=2002

|DecideDate=June 27

|DecideYear=2002

|FullName=Board of Education of Independent School District of Pottawatomie County, et al. v. Earls, et al.

|USVol=536

|USPage=822

|ParallelCitations=122 S. Ct. 2559; 153 L. Ed. 2d 735

|Prior=

|Subsequent=

|Holding=Coercive drug testing imposed by school district upon students who participate in extracurricular activities does not violate the Fourth Amendment.

|Majority=Thomas

|JoinMajority=Rehnquist, Scalia, Kennedy, Breyer

|Concurrence=Breyer

|Dissent=O'Connor

|JoinDissent=Souter

|Dissent2=Ginsburg

|JoinDissent2=Stevens, O'Connor, Souter

|LawsApplied=U.S. Const. amend. IV

}}

Board of Education v. Earls, 536 U.S. 822 (2002), was a case by the Supreme Court of the United States in which the Court held, 5–4, that it does not violate the Fourth Amendment to the U.S. Constitution for public schools to conduct mandatory drug testing on students participating in extracurricular activities.

The case centered around a policy adopted by the school district of Tecumseh, Oklahoma requiring all students involved in extracurricular activities, including the school's sports teams, to consent to urinalysis testing for drugs. Two students, Lindsay Earls and Daniel James, brought a lawsuit against the school board, alleging that the policy violated the Fourth Amendment's prohibition of unreasonable search and seizure.{{Cite web |title=Board of Ed. of Independent School Dist. No. 92 of Pottawatomie Cty. v. Earls |url=https://www.oyez.org/cases/2001/01-332 |access-date=2023-01-08 |website=Oyez |language=}}

Background

The Student Activities Drug Testing Policy adopted by the Tecumseh, Oklahoma School District requires all middle and high school students to consent to urinalysis testing for drugs in order to participate in any extracurricular activity. Two Tecumseh High School students and their parents brought suit, alleging that the policy violates the Fourth Amendment. The District Court granted the School District summary judgment. In reversing, the Court of Appeals held that the policy violated the Fourth Amendment. The appellate court concluded that before imposing a suspicionless drug-testing program, a school should demonstrate some identifiable drug abuse problem among a sufficient number of those tested, such that testing that group will actually redress its drug problem, which the School District failed to demonstrate.

Opinion of the Court

In a majority opinion delivered by Justice Clarence Thomas, the Court held that students in extracurricular activities had a diminished expectation of privacy, and that the policy furthered an important interest of the school in preventing drug use among students. This rationale was based on the precedent Vernonia School District 47J v. Acton (1995), which allowed drug testing for athletes. Justice Stephen Breyer filed an opinion concurring in the Court's judgment.