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York v. Wahkiakum School Dist. No. 200, 163 Wash.2d 297, 178 P.3d 995, 230 Ed. Law Rep. 425

Facts

The Wahkiakum School District implemented a policy requiring random drug testing for all student athletes due to concerns about substance abuse among students. Parents of student athletes Aaron and Abraham York and Tristan Schneider challenged the constitutionality of this policy, arguing it violated the Washington State Constitution's protection against unreasonable searches. The Superior Court initially upheld the policy, but the case was brought to the Supreme Court for direct review after the parents sought a summary judgment order. The Supreme Court ultimately found that the policy constituted an invasion of privacy without legal authority.

The Wahkiakum School District (school district) randomly drug tests all student athletes under the authority of Wahkiakum School Board Policy No. 3515 (policy 3515). Aaron and Abraham York and Tristan Schneider played sports for Wahkiakum High School, agreed to the policy, and were tested. Their parents (York and Schneider parents) sued the school district alleging its drug testing policy violated article I, section 7 of the Washington State Constitution.

Issue

Does the Wahkiakum School District's policy requiring random and suspicionless drug testing of student athletes violate article I, section 7 of the Washington State Constitution?

The question before us is whether random and suspicionless drug testing of student athletes violates article I, section 7 of the Washington State Constitution.

Rule

Under article I, section 7 of the Washington State Constitution, no person shall be disturbed in their private affairs without authority of law. A warrantless search is generally considered unreasonable unless it falls within narrowly defined exceptions. The court must determine if the state action constitutes a disturbance of private affairs and whether there is legal authority justifying the intrusion.

Analysis

The court analyzed whether the drug testing policy constituted a disturbance of the students' private affairs. It concluded that requiring students to provide urine samples intrudes upon their reasonable expectation of privacy. The court also examined whether the school district had the necessary authority of law to conduct such testing without a warrant. The school district's argument for a 'special needs' exception to the warrant requirement was rejected, as the court found no justification for such an exception in this context.

Because we determine that interfering with a student athlete's bodily functions disturbs one's private affairs, we must address the second prong of the article I, section 7 analysis: does the school district have the necessary authority of law to randomly drug test student athletes?

Conclusion

The Supreme Court held that the school district's policy allowing for random and suspicionless drug testing of student athletes violated the Washington State Constitution, reversing the lower court's decision.

School district's policy allowing for random and suspicionless drug testing of student athletes violated provision of State Constitution prohibiting the invasion of private affairs or the home without authority of law.

Who won?

The parents of the student athletes prevailed in this case. The Supreme Court determined that the school district's random drug testing policy was unconstitutional, emphasizing the importance of protecting students' privacy rights. The court's ruling reinforced the principle that students do not lose their constitutional rights at school and that any intrusion into their private affairs must be justified by legal authority.

The York and Schneider parents brought suit arguing the school district's policy violated the Washington State Constitution.

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