State v. Best, 201 N.J. 100 (2010)

It is the school environment and the need for safety, order, and discipline that is the underpinning for the school official-who has reasonable grounds to believe that a student possesses contraband-to conduct a reasonable search for such evidence. To be sure, a student may hide contraband in his or her clothing, purse, book bag, locker, or automobile. Consequently, we conclude that the reasonableness standard, and not the traditional warrant and probable cause requirements, applies to the school authorities' search of a student's automobile on school property.

We turn now to apply the reasonable grounds standard to the facts here. As noted, that standard requires that we first determine whether the school authority was justified to conduct a search at the inc That is, were there reasonable grounds for suspecting that the search would turn up evidence that the student violated or was violating either the law or the rules of the school?

Here, the vice principal met with a student, who appeared to be under the influence of drugs, and the student indicated that defendant had given him a green pill. That information was sufficient for the vice principal to interview defendant and, once defendant denied any knowledge, to search his clothing for contraband.

The second part of the test is whether the search conducted was reasonably related in scope to the circumstances that justified the interference in the first place. . The search of defendant's person revealed three white capsules in his pants pocket, but no green pills were found. Defendant then admitted that he sold a white pill to a student for five dollars, claiming the pill was a nutritional supplement. The vice principal next extended the search to defendant's locker, and when that proved unsuccessful, to defendant's car. It was reasonable for the vice principal to believe that defendant may have additional contraband in all areas accessible to him on school property, including his locker and his car. Consequently, the vice principal's search of defendant's car was reasonably related in scope to the various locations on school property that defendant might have placed the contraband-on his person, his locker, and his car.

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