The Supreme Court ruled today that Arizona public school officials violated the constitutional rights of a teenage girl when they searched her for prescription-strength ibuprofen.

"The issue here is whether a 13-year-old student's Fourth Amendment right was violated when she was subjected to a search of her bra and underpants by school officials acting on reasonable suspicion that she had brought forbidden prescription and over-the-counter drugs to school," Justice David Souter wrote for the 8-1 majority in Safford Unified School District v. Redding. "Because there were no reasons to suspect the drugs presented a danger or were concealed in her underwear, we hold that the search did violate the Constitution ...." The justices, however, overturned a federal appeals court decision that found the school official who performed the search could be held personally liable.

The majority found that the school official's suspicion that then-13-year-old Savana Redding was carrying prescription strength ibuprofen did not warrant the level of intrusion of a strip-search.

"Here, the content of the suspicion failed to match the degree of intrusion," Souter wrote. "[Safford Middle School Vice Principal Kerry] Wilson knew beforehand that the pills were prescription-strength ibuprofen and over-the-counter naproxen, common pain relievers equivalent to two Advil, or one Aleve. He must have been aware of the nature and limited threat of the specific drugs he was searching for, and while just about anything can be taken in quantities that will do real harm, Wilson had no reason to suspect that large amounts of the drugs were being passed around, or that individual students were receiving great numbers of pills.

"In sum," Souter continued, "what was missing from the suspected facts that pointed to Savana was any indication of danger to the students from the power of the drugs or their quantity, and any reason to suppose that Savana was carrying pills in her underwear. We think that the combination of these deficiencies was fatal to finding the search reasonable."

The U.S. Court of Appeals for the Ninth Circuit ruled last year that Wilson, the Safford vice principal, could be held personally liable for the strip search. Today, the Supreme Court, noting varying lower court outcomes on qualified immunity for public schools officials, concluded that Wilson is entitled to qualified immunity. The Court stated that the "cases viewing school strip searches are differently from the way we see them are numerous enough, with well-reasoned majority and dissenting opinions, to counsel doubt that we were sufficiently clear in the prior statement of law."

Scott Lemieux provides some analysis of Safford at Lawyers, Guns and Money.