St. Mary's Law Journal


Safford Unified Sch. Dist. No. 1 v. Redding (Redding III) represents a pivotal decision in school search and seizure jurisprudence, specifically regarding strip searches of students. Redding III establishes constraints specific to strip searches on the search and seizure authority of school officials. Redding III is intended to provide a uniform test for the judiciary and school officials when evaluating the reasonableness of strip searches of students. The Court explicitly interposed a “reliable knowledge” element requiring: (1) the degree to which known facts imply prohibited conduct; (2) the specificity of the information received; and (3) the reliability of its source. The Court reasoned that strip searches should not be initiated until the school has conducted a thorough investigation to ensure the reliability of the information available to determine if a strip search is justified. Redding III revealed that the constitutionality of strip searches does not depend on how much of a student’s body is seen during the search. Nonetheless, the Court reasoned that the content of the suspicion for a strip search must match the degree of intrusion. A general claim and research showing that students generally hide drugs in their underwear will not suffice. For a strip search to survive constitutional scrutiny, the school official must have reasonable grounds to suspect that the particular student to be searched is hiding drugs in his underwear. According to the Court, Redding III has settled the law on strip searches in schools, and school officials should not expect qualified immunity unless the school officials do their due diligence.


St. Mary's University School of Law