Supreme Court of the United States

Safford Unified School District #1 v. Redding

June 25, 2009557 U.S. 364

Summary

The Court held that school officials violated the Fourth Amendment by requiring a 13-year-old student to expose her breasts and pelvic area during a search for common pain-relief pills because the suspicion did not justify that degree of intrusion. The Court nevertheless held that the individual officials were entitled to qualified immunity because the unlawfulness of the search was not clearly established at the time. The Court remanded the school district’s potential municipal liability for consideration under the governing municipal-liability doctrine. Justice Stevens, joined by Justice Ginsburg, and Justice Ginsburg separately would have denied qualified immunity; Justice Thomas would have held that the search was constitutional.

Holding

  • Justification for searching Redding’s belongings and outer clothing. The information connecting Redding to pill distribution supplied reasonable suspicion to search her backpack and outer clothing.
  • Constitutionality of the underwear search. The search requiring Redding to expose her bra and underpants violated the Fourth Amendment.
  • Qualified immunity for the individual school officials. Wilson, Romero, and Schwallier were protected from liability by qualified immunity despite the constitutional violation.
  • School district municipal liability. The Court did not resolve the school district’s potential municipal liability and remanded that claim for consideration.

Docket 08-479

Cited authorities

  • CA11
  • CA11
  • Ariz. Rev. Stat. Ann. §13
  • Mo. Rev. Stat. §577.628
  • Utah Code Ann. §58
  • Ala. Code §34
  • Fla. Stat. §499.005
  • N.H. Rev. Stat. Ann. §318:42

Cited by