State v. A. J. C.

Summary

The Oregon Supreme Court considered whether the school-safety exception to the warrant requirement permitted a high school principal to search a student's backpack after receiving a specific threat that the student would bring a gun to school. The court held that the principal reasonably suspected an immediate safety threat and that the limited search of compartments capable of containing a firearm was reasonable under Article I, section 9, of the Oregon Constitution. The court affirmed the Court of Appeals and the juvenile court's judgment.

Holdings

1. A school official may conduct a limited warrantless search when, based on specific and articulable facts, the official reasonably suspects that a person on school property possesses an item posing an immediate threat to students, staff, or others, and the particular search is reasonable under the totality of the circumstances.
2. The fact that the principal had secured the backpack and that the youth was calm and compliant did not, by itself, eliminate the immediate safety threat or make a limited search unreasonable.

Questions Presented

1. Whether the school-safety exception to the warrant requirement under Article I, section 9, of the Oregon Constitution permitted the principal to conduct a warrantless search of the youth's backpack after taking control of it.
2. Whether the immediate safety threat had dissipated because the backpack was secured and the youth was calm and compliant, such that a further search required additional facts, such as the youth reaching for the backpack.

Disposition

affirmed