State v. A.J.C.

The school safety exception applies where the school has "reasonable suspicion that there w[ere] imminent health or safety threats or risk to the students [of] the school"; an imminent safety threat needs to be supported by specific and articulable facts but is accompanied by additional considerations for this exception including the confined close-quarters of a school campus and the heightened standard of care to students and adults in the environment.

On review, the Juvenile asked whether the school safety exception to the warrant requirement permitted a school principal to conduct a warrantless search of Juvenile's backpack after the principal seized the backpack. Juvenile told another student he was going to bring a gun to school. Principal brought Juvenile into his office and told him he needed to investigate the threat. Juvenile did not consent to principal searching his backpack. Juvenile moved to suppress the evidence at trial, arguing the school safety exception did not apply. The juvenile court concluded that the school safety exception applies where the school has "reasonable suspicion that there w[ere] imminent health or safety threats or risk to the students [of] the school." Juvenile argued to this Court that the search was no longer justified because he no longer posed an immediate safety risk. The correct evaluation is whether the particular steps were reasonable under the particular circumstances; within the school safety exception, an imminent safety threat supported by specific and articulable facts is accompanied by additional considerations including the confined close-quarters of a school campus, the heightened standard of care to students and adults in the environment, and in this case, the articulated threat of violence in a school. Under the totality of the circumstances, the information known to the principal at the time of the search was sufficient for him to reasonably believe Juvenile possessed a firearm for the purpose of shooting one or more students. Therefore, it was reasonable for the principal to make reasonable efforts to find the gun and eliminate the threat, including conducting a limited search of the Juvenile's backpack. The decision of the Court of Appeals and the judgment of the circuit court were affirmed.