Safford Unified School District 1 v. Redding
Headline: Court rules strip search of 13-year-old unconstitutional but protects the school official with qualified immunity, narrowing when schools may perform invasive searches and leaving district liability for later review.
Holding: The Court held that the strip search of a 13-year-old violated the Fourth Amendment, but the official who ordered it is protected by qualified immunity and the school district’s liability is remanded for further consideration.
- Limits when schools may order students to expose underwear or private areas.
- Affirms that backpacks and outer clothing can be searched on reasonable suspicion.
- School employees may be shielded from damages if law was not clearly established.
Summary
Background
A 13-year-old student, Savana Redding, was taken to the assistant principal’s office after a classmate was found with pills and said they came from Savana. School staff found four prescription-strength ibuprofen pills and one over-the-counter naproxen pill in a day planner. Officials searched Savana’s backpack and outer clothes, finding nothing. School staff then had her pull her bra and the elastic of her underpants, exposing her breasts and pelvic area; no pills were found. Savana’s mother sued the school district and three staff members for an unconstitutional strip search.
Reasoning
The Court asked whether the underwear search was reasonable under the rule that school searches need only reasonable suspicion (a moderate chance of finding evidence). The Justices held the search of her underwear was unconstitutional because there was no reason to believe the pills were dangerous or hidden in her underclothes. The Court said searches of backpacks and outer clothing were justified. But the official who ordered the underwear search received qualified immunity (legal protection from damages) because lower courts had reached different conclusions and the right was not clearly established. The Court left open the school district’s separate liability claim for later consideration.
Real world impact
The ruling makes clear that invasive body searches of students demand specific supporting facts, like danger or a reason to think evidence is hidden on the body. Schools can still search bags and outer clothing on reasonable suspicion. Individual staff may avoid personal liability when the law was not clearly settled. The district’s responsibility remains to be decided.
Dissents or concurrances
Two Justices would have denied immunity, saying prior law clearly barred the strip search; another Justice would have found the search lawful.
Opinions in this case:
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