Brief of Amici Curiae Juvenile Law Center, Center for Juvenile Law and Policy, Center on Wrongful Convictions of Youth, and Children’s Law Center, Inc., et al. on Behalf of Appellee Joshua Polk
Marsha L. Levick
Sherri Bevan Walsh
SimpleOriginal

Summary

Amici curiae emphasize the importance of preserving students' Fourth Amendment rights within the educational system.

2016 | State Juristiction

Brief of Amici Curiae Juvenile Law Center, Center for Juvenile Law and Policy, Center on Wrongful Convictions of Youth, and Children’s Law Center, Inc., et al. on Behalf of Appellee Joshua Polk

Keywords Fourth Amendment (U.S.); exclusionary rule; law enforcement; illegal school searches; school-to-prison-pipeline
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Summary of Argument

Amici curiae write to ensure the Supreme Court’s decree that “students do not ‘shed their Constitutional rights . . . at the schoolhouse gate,’” Tinker v. Des Moines Indep. Cmty. Sch. Dist., 393 U.S. 503, 506 (1969), continues to have meaning in Ohio. It is through the educational system that our children learn the moral, social and civic values that drive the interaction between citizens and government. While the United States Supreme Court has recognized that children’s constitutional rights may in some instances be articulated differently from adult rights in comparable circumstances, no decision from the Supreme Court or this Court suggests that school children forfeit their rights to our most fundamental constitutional guarantees merely by crossing the school threshold.

Yet, the State and its Amici seek through this case to drastically circumscribe children’s Fourth Amendment rights by barring application of the only remedy the Supreme Court has crafted to prevent Fourth Amendment violations—the exclusionary rule—for any illegal search conducted by school officials. Such a bold and effectively unprecedented decision would render the Fourth Amendment meaningless for Ohio’s school children. No such sweeping erosion of children’s Fourth Amendment rights is justified.

Amici reject all three propositions of law proposed by the State. For the first proposition, Amici support and incorporate the argument of Appellee Joshua Polk.

On the second proposition of law, Amici write to underscore the importance of the exclusionary rule, and to stress that it applies to illegal searches conducted by school officials. The State’s argument that school officials are not deterred by the threat of the exclusionary rule because they are completely divorced from law enforcement does not comport with contemporary school culture, in which police and “school resource officers” are increasingly present on school campuses and schools refer hundreds of thousands of students to law enforcement each year.

With respect to the third proposition of law, Amici argue that the State overstates the cost- benefit analysis courts must apply in determining whether to apply the exclusionary rule. In cases like this one, in which a state official’s actions are sufficiently culpable, the deterrent effect is strong and there is no need to conduct a deeper balancing test. Moreover, eliminating the exclusionary rule in school search cases would undermine those students’ respect for the Constitution and the civic responsibilities schools are supposed to engender, while contributing to the “school-to-prison-pipeline” epidemic plaguing our country—all this without any demonstrable improvement in student safety.

The trial court and Court of Appeals correctly rejected the State’s dangerous call to bar the exclusionary rule in school search cases. We urge this Court to do the same.

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Summary of Argument

Amici curiae submit this brief to ensure the Supreme Court's decree that students retain their Constitutional rights in educational settings remains relevant in Ohio. The Amici argue that the educational system plays a crucial role in imparting the moral, social, and civic values that underpin the relationship between citizens and the government. While acknowledging that children's constitutional rights may differ from those of adults in certain contexts, they emphasize that the Supreme Court has never suggested that students forfeit their fundamental rights upon entering school.

The Amici express concern that the State's attempt to restrict the application of the exclusionary rule for illegal searches conducted by school officials would effectively render the Fourth Amendment meaningless for Ohio's schoolchildren. They reject the State's argument that school officials are not subject to the deterrent effect of the exclusionary rule, arguing that the increasing presence of police and "school resource officers" on school campuses necessitates the application of this crucial safeguard.

Furthermore, the Amici contend that the State's proposed cost-benefit analysis for the exclusionary rule ignores the substantial deterrent effect it provides in cases of official misconduct. They argue that eliminating the exclusionary rule in school search cases would undermine students' respect for the Constitution and contribute to the "school-to-prison-pipeline" epidemic, without any demonstrable improvement in student safety.

The Amici conclude by urging the Court to uphold the trial court and Court of Appeals' decisions in rejecting the State's attempt to bar the exclusionary rule in school search cases.

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Summary of Argument

Amici curiae argue that the Fourth Amendment rights of students remain relevant in Ohio schools. They assert that the Supreme Court's recognition of student rights in Tinker v. Des Moines Indep. Cmty. Sch. Dist. is fundamental to the educational system and the development of civic values. While acknowledging that children's constitutional rights may be expressed differently than adult rights, Amici argue that school children retain their fundamental constitutional guarantees.

Amici oppose the State's efforts to limit student Fourth Amendment rights by eliminating the exclusionary rule for searches conducted by school officials. They contend that such an unprecedented move would effectively nullify the Fourth Amendment for Ohio's students.

Regarding the State's proposed propositions, Amici support Appellee Joshua Polk's argument in response to the first proposition. In regard to the second proposition, Amici emphasize the importance of the exclusionary rule in deterring illegal searches, even by school officials. They dispute the State's claim that school officials are insulated from the exclusionary rule due to their separation from law enforcement, highlighting the increasing presence of police and school resource officers on campuses and the referral of numerous students to law enforcement each year.

Concerning the third proposition, Amici argue that the State exaggerates the cost-benefit analysis used to determine the application of the exclusionary rule. In cases where official misconduct is significant, the deterrent effect of the rule is strong, rendering a complex balancing test unnecessary. Amici further contend that eliminating the exclusionary rule in school search cases would undermine students' respect for the Constitution, contribute to the "school-to-prison-pipeline" issue, and ultimately fail to demonstrably enhance student safety.

In conclusion, Amici urge the Court to uphold the trial court and Court of Appeals' decision in rejecting the State's proposal to bar the exclusionary rule in school search cases.

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Summary of Argument

In this case, the State is trying to limit the Fourth Amendment rights of students by saying that the exclusionary rule, which prevents evidence from being used in court if it was obtained illegally, doesn’t apply to searches done by school officials. The Amici argue that this would make the Fourth Amendment meaningless for Ohio students.

Amici disagree with the State's arguments and believe that the exclusionary rule should apply to searches by school officials. They argue that police and school resource officers are becoming increasingly common in schools, and that many students are referred to law enforcement each year.

They also argue that removing the exclusionary rule in school search cases would undermine students’ respect for the Constitution and lead to a "school-to-prison-pipeline" epidemic. Amici urge the Court to uphold the lower courts' decision to keep the exclusionary rule in place for school searches.

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Summary of Argument

This document is about a court case about the rights of students in Ohio schools. The people writing this document are arguing that students' rights are important and should be protected. They believe that students have the same rights as adults and that these rights should not be taken away just because they are in school. They are arguing against the state, who is trying to make it harder for students to challenge illegal searches by school officials. They believe that the state's proposal is wrong because it would make the Fourth Amendment, which protects people from unreasonable searches and seizures, meaningless for students in Ohio.

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Footnotes and Citation

Cite

Brief of Amici Curiae Juvenile Law Center, Center for Juvenile Law and Policy, Center on Wrongful Convictions of Youth, Children’s Law Center, Inc., Rutgers School of Law Children’s Justice Clinic, Rutgers Criminal and Youth Justice Clinic, Education Law Center-PA, Professor Barry C. Feld, Juvenile Defenders Association of Pennsylvania, Juvenile Justice Initiative, National Center for Youth Law, National Juvenile Justice Network, Northeast Juvenile Defender Center, Roderick and Solange MacArthur Justice Center, and Youth Law Center on Behalf of Appellee Joshua Polk, State v. Polk, No. 14-AP-787 (Ohio Sup. Ct. Sept. 14, 2016).

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