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    EARLS v BOARD OF EDUCATION OF TECUMSEH  PUBLIC SCHOOL DISTRICT
                                            FILED
                               United States Court of Appeals
                                        Tenth Circuit
      
                                         MAR 21 2001
      
                                       PATRICK FISHER
                                            Clerk                                      PUBLISH
             
                               UNITED STATES COURT OF APPEALS
             
                                       TENTH CIRCUIT
             
             
             
             LINDSAY EARLS and LACEY EARLS,  minors,  
             by their next friends and parents, John  
             David Earls and Lori Earls; DANIEL JAMES,
             a  minor, by his friend and mother, Leta 
             Hagar,                                   
                                                      
                       Plaintiffs - Appellants,                 
                                                      
    
                  v.                                              No. 00-6128
                                                      
    
             BOARD OF EDUCATION OF TECUMSEH  PUBLIC 
             SCHOOL DISTRICT, Independent  School 
             District No. 92 of Pottawatomie County;  
             TECUMSEH PUBLIC SCHOOL DISTRICT,  
             Independent School District No. 92 of  
             Pottawatomie County,
                                                      
                       Defendants - Appellees.                  
             __________________________________________
             
             
             
             
             OKLAHOMA STATE SCHOOL BOARDS  
             ASSOCIATION; NATIONAL SCHOOL BOARDS 
             ASSOCIATION; WASHINGTON  LEGAL 
             FOUNDATION; U.S. SENATORS JUDD GREGG 
             and DON NICKLES;  GOVERNOR FRANK 
             KEATING; REP. FRED S. MORGAN 
             (Oklahoma); OKLAHOMA  SECONDARY 
             SCHOOLS ACTIVITIES  ASSOCIATION; ALLIED 
             EDUCATIONAL  FOUNDATION; GAYLA D. 
             DUKE; RHONDA ELLARD; DEBRA FLETCHER; 
             BOBBETTE HAMILTON; JIMMY and SHEILA 
             JORDAN; MICHAEL and KIM RAWLS; 
             STEWART and  ROSHEL STABEL; KENNETH 
             A. STANLEY;  KRIS STEELE; CLYDE L. and 
             GAIL A. TOPPING; MIKE and VALERIE
             TUCKER;  STEVE and LYNNE YOUNG; THE  
             AMERICAN PUBLIC HEALTH  ASSOCIATION; 
             THE NATIONAL  ASSOCIATION OF SOCIAL 
             WORKERS; THE NATIONAL ASSOCIATION OF 
             SOCIAL WORKERS ? OKLAHOMA CHAPTER; 
             THE  CENTER FOR LAW AND EDUCATION; THE
             NATIONAL CENTER FOR YOUTH LAW;  THE 
             JUVENILE LAW CENTER; THE  LOYOLA 
             CHILDLAW CENTER;  ADVOCATES FOR
             CHILDREN OF NEW  YORK; LAWYERS FOR 
             CHILDREN; COVENANT HOUSE NEW JERSEY;
             PROFESSOR MARTIN GUGGENHEIM &  
             PROFESSOR RANDY HERTZ; AMERICAN  
             ACADEMY OF PEDIATRICS,
                                                      
                       Amici Curiae.
                                                      
    
                                             
                                                      
         
             
             
                        APPEAL FROM THE UNITED STATES DISTRICT COURT
                            FOR THE WESTERN DISTRICT OF OKLAHOMA
                                  (D.C. NO. CV-99-1213-R)
             
             
             
             Graham A. Boyd, American Civil Liberties Union Foundation, New Haven, 
             Connecticut, for Plaintiffs-Appellants.
             
             Linda Maria Meoli (William P. Bleakley and Stephanie J. Mather with her on the 
             brief), The Center for Education Law, Inc., Oklahoma City, Oklahoma, for 
             Defendants-Appellees.                        
             
             Craig R. Levine, New York, New York, filed an amici curiae brief for The 
             American Public Health Association, The National Association of Social 
             Workers, The National Association of Social Workers - Oklahoma Chapter, The 
             Center for Law and Education, The National Center for Youth Law, The Juvenile 
             Law Center, The Loyola ChildLaw Center, Advocates for Children of New York, 
             Lawyers for Children, Covenant House New Jersey, Professor Martin 
             Guggenheim & Professor Randy Hertz, and American Academy of Pediatrics.
    
     
             
             Tyson L. Williams and Julie L. Vogt, Oklahoma State School Boards Association, 
             Oklahoma City, Oklahoma; Julie K. Underwood and Edwin C. Darden, National 
             School Boards Association, Alexandria, Virginia, filed an amici curiae brief for 
             The Oklahoma State School Boards Association and The National School Boards 
             Association.
             
             Daniel J. Popeo and R. Shawn Gunnarson, Washington Legal Foundation, 
             Washington, D.C., filed an amici curiae brief for Washington Legal Foundation; 
             U.S. Senators Judd Gregg and Don Nickles; Governor Frank Keating; Rep. 
             Fred S. Morgan (Oklahoma); Oklahoma Secondary Schools Activities 
             Association; Allied Educational Foundation; Gayla D. Duke; Rhonda Ellard; 
             Debra Fletcher; Bobbette Hamilton; Jimmy and Sheila Jordan; Michael and Kim 
             Rawls; Stewart and Roshel Stabel; Kenneth A. Stanley; Kris Steele; Clyde L. and 
             Gail A. Topping; Mike and Valerie Tucker; and Steve and Lynne Young.
             
             
             
             Before BRORBY, ANDERSON, and EBEL, Circuit Judges.
             
             
             
             ANDERSON, Circuit Judge.
             
             
             
             
    
                  Plaintiffs Lindsay Earls and Daniel James are students at Tecumseh High 
    
             School.(1)  By their next friends and parents, John David and Lori Earls and Leta 
    
             Hagar, they brought this 42 U.S.C. § 1983 action against the Board of Education 
    
             of the Tecumseh Public School District and the Tecumseh Public School District 
    
             (collectively the "District"), challenging the constitutionality of the random 
    
             suspicionless urinalysis drug testing policy which the District implemented for all 
    
             students participating in competitive extracurricular activities.  The district court
             
    
    
    
    
    
             (1)     Lacey Earls was added as a plaintiff shortly before the district court issued 
             its judgment in this case.
             
     
             granted summary judgment in favor of the District, concluding that the policy 
    
             does not violate the Fourth Amendment's prohibition against unreasonable 
    
             searches.  Plaintiffs appeal that decision.
    
                  We have received three amicus briefs:  one from The American Public 
    
             Health Association, The National Association of Social Workers, The National 
    
             Association of Social Workers?Oklahoma Chapter, The Center for Law and 
    
             Education, The National Center for Youth Law, The Juvenile Law Center, The 
    
             Loyola ChildLaw Center, Advocates for Children of New York, Lawyers for 
    
             Children, Covenant House New Jersey, Professor Martin Guggenheim, Professor 
    
             Randy Hertz, and the American Academy of Pediatrics, in support of plaintiffs; 
    
             one from The Oklahoma State School Boards Association and The National 
    
             School Boards Association, in support of the District; and one from the 
    
             Washington Legal Foundation, United States Senators Judd Gregg and Don 
    
             Nickles, Governor Frank Keating, Representative Fred S. Morgan, the Oklahoma 
    
             Secondary Schools Activities Association, the Allied Educational Foundation, 
    
             Gayla D. Duke, Rhonda Ellard, Debra Fletcher, Bobbette Hamilton, Jimmy and 
    
             Sheila Jordan, Michael and Kim Rawls, Stewart and Roshel Stabel, Kenneth A. 
    
             Stanley, Kris Steele, Clyde L. and Gail A. Topping, Mike and Valerie Tucker, 
    
             and Steve and Lynne Young, in favor of the District.
    
                  Because we conclude that the policy violates the Fourth Amendment, we 
    
             reverse and remand this case.
    
    
     
             
    
                                         BACKGROUND
    
                  Tecumseh High School has for many years offered a variety of 
    
             extracurricular activities for students interested in participating therein.  Such 
    
             activities have included the choir, band, color guard, Future Farmers of America 
    
             ("FFA"), Future Homemakers of America ("FHA"), and the academic team. 
    
             Additionally, it has also sponsored athletic teams, cheerleaders and Pom Pon.(2) 
    
             "The vast majority of students participate in one or more school-sponsored 
    
             activities."  Earls v. Bd. of Educ., 115 F. Supp. 2d 1281, 1282 (W.D. Okla. 
    
             2000). 
    
                  On September 14, 1998, the District adopted the Student Activities Drug 
    
             Testing Policy (the "Policy") requiring drug testing of all students who 
    
             participate "in any extra-curricular activity such as FFA, FHA, Academic Team, 
    
             Band, Vocal, Pom Pon, Cheerleader and Athletics."  Tecumseh Public Schools 
    
             Student Activities Drug-testing Policy at 2, Appellants' App. Vol. I at 107.  Each 
    
             student seeking to participate in such activities must sign a written consent 
    
             agreeing to submit to drug testing prior to participating in the activity, randomly 
    
             during the year while participating, and at any time while participating upon 
    
             reasonable suspicion.  The test detects amphetamines, cannabinoid metabolites 
    
             (marijuana), cocaine, opiates, barbiturates and benzodiazepines.  It does not
             
    
    
    
    
    
             (2)     The drug testing policy itself and the district court's opinion both describe 
             this activity as Pom Pon.  We accordingly refer to it that way in this opinion.
             
     
             detect alcohol or nicotine.  Students subject to the Policy must pay a yearly fee of 
    
             four dollars.  Although the Policy does not expressly so state, it is undisputed 
    
             that the Policy has in fact only been applied to those extracurricular activities 
    
             involving some aspect of competition and which are sanctioned by the Oklahoma 
    
             Secondary Schools Activity Association ("OSSAA").
    
                  The district court described the actual drug testing process as follows, 
    
             which the parties do not dispute:
    
                  [T]he students to be tested are called out of class in groups of two or 
                  three.  The students are directed to a restroom, where a faculty 
                  member serves as a monitor.  The monitor waits outside the closed 
                  restroom stall for the student to produce the sample.  The monitor 
                  pours the contents of the vial into two bottles.  Together, the faculty 
                  monitor and the student seal the bottles.  The student is given a form 
                  to sign, which is placed, along with the filled bottles, into a mailing 
                  pouch in the presence of the student.  Random drug testing was 
                  conducted in this manner on approximately eight occasions during 
                  the 1998/1999 school year.  Approximately twenty students were 
                  tested each time.
             
             Earls, 115 F. Supp. 2d at 1290-91.  At the time of the testing, the monitor also 
    
             gives each student a form on which he or she may list any medications legally 
    
             prescribed for the student.  According to the Policy, "[t]he medication list shall 
    
             be submitted to the lab in a sealed and confidential envelope and shall not be 
    
             viewed by district employees."  Policy at 5, Appellants' App. Vol. I at 110.
    
                  The results of the drug tests are placed in confidential files separate from 
    
             the students' other educational files.  They "shall be disclosed only to those 
    
             school personnel who have a need to know, and will not be turned over to any
             
     
             law enforcement authorities."  Id.  Students who refuse to submit to the drug 
    
             testing under the Policy are prohibited from participating in any extracurricular 
    
             activities.  There are no academic sanctions imposed.
    
                  Plaintiff Lindsay Earls is a member of the show choir, the marching band 
    
             and the academic team.  Plaintiff Daniel James apparently seeks to participate in 
    
             the academic team and was enrolled during the 1999-2000 school year in the 
    
             academic team class.  They and their parents challenge the application of the 
    
             Policy to them as a condition to their participation in those activities.  Plaintiffs 
    
             do not challenge the policy as it applies to athletes.
    
             
    
                                         DISCUSSION
    
                  We review de novo the district court's grant of summary judgment.  Phelan 
    
             v. Laramie County Cmty. Coll. Bd. of Trs., 235 F.3d 1243, 1246 (10th Cir. 
    
             2000).  Accordingly, summary judgment is appropriate "if the pleadings, 
    
             depositions, answers to interrogatories, and admissions on file, together with 
    
             affidavits, if any, show that there is no genuine issue as to any material fact and 
    
             that the moving party is entitled to judgment as a matter of law."  Fed. R. Civ. P. 
    
             56(c).  When we apply this standard, we examine the record and any reasonable 
    
             inferences drawn therefrom in the light most favorable to the non-moving party. 
    
             19 Solid Waste Dept. Mechs. v. City of Albuquerque, 156 F.3d 1068, 1071 (10th 
    
             Cir. 1998). 
    
    
     
                  The Fourth Amendment ordinarily requires "some quantum of 
    
             individualized suspicion" before a search may constitutionally proceed.  United 
    
             States v. Martinez-Fuerte, 428 U.S. 543, 560 (1976).  However, the Supreme 
    
             Court has recognized that "the Fourth Amendment imposes no irreducible 
    
             requirement of such suspicion."  Id. at 561.  Rather, "the ultimate measure of the 
    
             constitutionality of a governmental search is `reasonableness.'"  Vernonia Sch. 
    
             Dist. v. Acton, 515 U.S. 646, 652 (1995).  The Court has further held that the 
    
             "state-compelled collection and testing of urine" is a search subject to the Fourth 
    
             Amendment's reasonableness requirement.  Id. (citing Skinner v. Ry. Labor 
    
             Execs. Ass'n, 489 U.S. 602, 617 (1989)).
    
                  Because we are presented in this case with a Fourth Amendment search of 
    
             school children while at school, we first examine the general nature of the rights 
    
             and obligations of students and school personnel in the school setting.  It is 
    
             "indisputable . . . that the Fourteenth Amendment protects the rights of students 
    
             against encroachment by public school officials."  New Jersey v. T.L.O., 469 
    
             U.S. 325, 334 (1985).  As state actors, therefore, school personnel "do not merely 
    
             exercise authority voluntarily conferred on them by individual parents; rather, 
    
             they act in furtherance of publicly mandated educational and disciplinary 
    
             policies."  Id. at 336.  However, while school authorities do not act merely in 
    
             loco parentis when interacting with students, the Court has made it clear that 
    
             their power over students is "custodial and tutelary, permitting a degree of
             
     
             supervision and control that could not be exercised over free adults."  Vernonia, 
    
             515 U.S. at 655.  Thus, while students retain their Fourth Amendment right to be 
    
             free from unreasonable searches while at school, the nature of that right is 
    
             different?it "is what is appropriate for children in school."  Id. at 656.  It is in 
    
             this unique environment that we examine the constitutionality of the Policy.
    
                  The District justifies the Policy based on the "special needs" doctrine, 
    
             which the Supreme Court has developed through a series of cases permitting 
    
             suspicionless drug testing in certain situations.  In Skinner v. Ry. Labor Exec. 
    
             Ass'n, 489 U.S. 602 (1989), the Court upheld the suspicionless drug testing of 
    
             railroad employees who had been involved in accidents.  It explained the "special 
    
             needs" doctrine as follows:
    
                  We have recognized exceptions to . . . [the warrant requirement] 
                  when special needs, beyond the normal need for law enforcement, 
                  make the warrant and probable-cause requirement impracticable. 
                  When faced with such special needs, we have not hesitated to 
                  balance the governmental and privacy interests to assess the 
                  practicality of the warrant and probable-cause requirements in the 
                  particular context.
             
             Id. at 619 (quotations omitted).  Accordingly, under the special needs doctrine, 
    
             the Court identifies a special need which makes impracticable adherence to the 
    
             warrant and probable cause requirements, then balances the government's interest 
    
             in conducting the particular search against the individual's privacy interests upon 
    
             which the search intrudes.
    
    
     
                  Employing that analysis, in Nat'l Treasury Employees Union v. Von Raab, 
    
             489 U.S. 656 (1989), the Court upheld Customs Service regulations requiring 
    
             suspicionless drug testing for Customs Service employees seeking positions 
    
             involving the interdiction of illegal drugs or requiring the carrying of firearms. 
    
             In Vernonia, again invoking the special needs doctrine, the Court upheld the 
    
             suspicionless drug testing of student athletes at a high school and middle school. 
    
             Finally, in Chandler v. Miller, 520 U.S. 305 (1997), finding that Georgia had 
    
             failed to demonstrate a "special need" justifying the particular search at issue, the 
    
             Court held unconstitutional a Georgia statute requiring candidates for certain 
    
             public offices to certify that they had taken a urinalysis test within thirty days 
    
             prior to qualifying for nomination or election and that the test was negative.  
    
                  Chandler was the first case in which the Court found the government failed 
    
             to demonstrate a special need.  Our court has recently held that in Chandler, "the 
    
             Court added a step to the analysis it had followed in Skinner, Von Raab, and 
    
             [Vernonia]."  19 Solid Waste Dept. Mechs., 156 F.2d at 1072.  We held that 
    
             Chandler requires courts to inquire first into whether the government has 
    
             established the existence of a special need before proceeding to any balancing of 
    
             government and private interests.  We defined that inquiry as two-fold:  first, 
    
             "whether the proffered governmental concerns were `real' by asking whether the 
    
             testing program was adopted in response to a documented drug abuse problem or 
    
             whether drug abuse among the target group would pose a serious danger to the
             
     
             public"; and second, "whether the testing scheme met the related goals of 
    
             detection and deterrence."  Id. at 1073.  These special needs cases provide the 
    
             parameters for our analysis.(3)
    
                  The parties argue vigorously over which of these cases should primarily 
    
             guide our decision in this case.  Plaintiffs argue that Chandler, as interpreted by 
    
             our court in 19 Solid Waste Mechs., governs and compels the conclusion that the 
    
             District has failed to establish the existence of a special need.  They argue that 
    
             the existence of a special need is a threshold test; the District has failed to 
    
             demonstrate such a need because it has failed to show that a drug problem exists 
    
             among the tested group; and we therefore need not even reach the balancing 
    
             analysis.  However, they argue, were we to reach the balancing analysis, we 
    
             would still conclude that the Policy is unconstitutional.
    
                  The District responds that Vernonia remains the authoritative guide for a 
    
             case such as this involving an allegation of special need for a suspicionless 
    
             search in a public school environment.  It argues that a special need exists 
    
             because the District did in fact demonstrate the existence of a drug problem at the 
    
             school.  Further, the balancing analysis would compel the conclusion that the 
    
             Policy is constitutional.
    
    
    
    
    
             (3)     The Supreme Court's special needs cases have engendered some criticism 
             for failing to adequately define what a special need is.  See, e.g., Robert D. 
             Dodson, Ten Years of Randomized Jurisprudence:  Amending the Special Needs 
             Doctrine, 51 S.C.L. Rev. 258, 261 (Winter 2000). 
             
     
                  We begin by noting that, while there may indeed be some confusion as to 
    
             the application of the special needs doctrine in other settings, we deal here with 
    
             the unique environment of the school setting.  Thus, we take Vernonia, the only 
    
             Supreme Court case involving suspicionless drug testing of a group of students at 
    
             a public school, as the primary guide for our analysis of this case.  As the 
    
             Supreme Court explicitly stated in Vernonia, "[w]e have found . . . `special 
    
             needs' to exist in the public school context," where adherence to the traditional 
    
             Fourth Amendment requirements of a warrant and probable cause "`would unduly 
    
             interfere with the maintenance of swift and informal disciplinary procedures [that 
    
             are] needed,'" and would undermine "`the substantial need of teachers and 
    
             administrators for freedom to maintain order in the schools.'"  Vernonia, 515 
    
             U.S. at 653 (quoting T.L.O., 469 U.S. at 340-41).  Whether or not the Supreme 
    
             Court has raised the special need bar in other contexts, we must assume, until the 
    
             Court directs us otherwise, that its analysis in Vernonia governs our analysis in 
    
             this case.  Thus, we agree that the District has demonstrated that there is a 
    
             special need for a relaxation of the Fourth Amendment's standards in this case, 
    
             and conclude that the constitutionality of the Policy will be determined by 
    
             balancing the factors set forth in Vernonia.(4)  See Gruenke v. Seip, 225 F.3d 290,
             
    
    
    
    
    
    
    
             (4)     Were we to agree with the plaintiffs that Chandler and 19 Solid Waste 
             Mechs. have raised the special need bar in all cases, including those involving 
             public school contexts, we would still conclude that the District has demonstrated
             the existence of a special need.  
             
                  As we stated in 19 Solid Waste Mechs., the Chandler Court in addressing 
             the special need inquiry first "examined whether the proffered governmental 
             concerns were `real' by asking whether the testing program was adopted in 
             response to a documented drug abuse problem or whether drug abuse among the 
             target group would pose a serious danger to the public."  19 Solid Waste Mechs., 
             156 F.3d at 1073.  Just as with Customs Service employees in Von Raab, the 
             Court in Chandler, and our court in 19 Solid Waste Mechs., recognized that, even 
             without a documented drug abuse problem, the potential danger of drug abuse 
             among the target group may be sufficient to establish the existence of a special 
             need.  While drug abuse among a large portion of a school student body does not 
             present the same kind of public safety danger as the Court surmised drug abuse 
             among certain Customs Service employees could, it nonetheless would 
             undeniably be a serious societal problem.  Thus, we think a school concerned 
             about drug abuse among its students has adequately demonstrated the existence of 
             a special need.  Of course, once a special need has been demonstrated, we must 
             then balance the government's (in this case, the school's) interest in conducting 
             the particular search in question against the privacy interests of those subject to 
             the search.    
             
     
             300-01 (3d Cir. 2000) ("[I]n other circumstances, there may be `special needs' 
    
             that make probable cause impracticable.  The public school context is one of 
    
             those settings.").  We turn, therefore, to an examination of Vernonia.
    
                  Significantly, the Court in Vernonia began its opinion by describing the 
    
             serious drug problem which had developed in the Vernonia schools.  While drugs 
    
             had not previously been a major problem, `[i]n the mid-to-late 1980's . . . 
    
             teachers and administrators observed a sharp increase in drug use."  Vernonia, 
    
             515 U.S. at 648.  "Along with more drugs came more disciplinary problems."  Id.   
             
             Moreover, "athletes were the leaders of the drug culture."  Id. at 649.  The Court 
    
             adopted the following district court findings:
    
                  [T]he administration was at its wits end and . . . a large segment of 
                  the student body, particularly those involved in interscholastic 
                  athletics, was in a state of rebellion.  Disciplinary actions had 
                  reached "epidemic proportions."  The coincidence of an almost 
                  threefold increase in classroom disruptions and disciplinary reports 
                  along with the staff's direct observations of students using drugs or 
                  glamorizing drug and alcohol use led the administration to the 
                  inescapable conclusion that the rebellion was being fueled by alcohol 
                  and drug abuse as well as the student's misperceptions about the 
                  drug culture.
             
             Id.(5)  Faced with this indisputably serious and widespread drug problem, the 
    
             Vernonia schools adopted a suspicionless drug testing policy.  The policy, which 
    
             was administered in a manner very similar to the Policy in our case, applied to all 
    
             students participating in interscholastic athletics.
    
                  The Court then reviewed its special needs doctrine, and stated, without 
    
             more, "[w]e have found such `special needs' to exist in the public school 
    
             context."  Id. at 653.(6)  The Court proceeded to consider the various factors
             
    
    
    
    
             (5)     Although Justice O'Connor's dissent in Vernonia questioned the 
             sufficiency of the evidence in the record of a drug problem at the Vernonia 
             middle school which the plaintiff attended when he filed suit against the school 
             district, the majority's opinion adopts and relies upon the district court's findings 
             about a serious drug problem in the Vernonia high schools.  One cannot read the 
             majority opinion and not appreciate that those factual findings regarding the 
             existence of a documented drug problem among students subject to the drug 
             testing were very important to the majority.   
             (6)     What is unclear from a simple reading of Vernonia is whether the Court's
             finding of a special need was based upon the school setting alone, with the 
             concomitant need for school officials to maintain order and discipline, yet fulfill 
             their tutelary and custodial obligations, or whether it was based upon that need in 
             conjunction with the documented serious drug problem at the Vernonia schools. 
             
     
             relevant to the required balancing of the search's "intrusion on the individual's 
    
             Fourth Amendment interests against its promotion of legitimate governmental 
    
             interests."  Id. (quoting Skinner, 489 U.S. at 619).
    
                  The Court explained that "[t]he first factor to be considered is the nature of 
    
             the privacy interest upon which the search . . . intrudes."  Id. at 654.  The Court 
    
             reiterated the primacy of the school setting:  "[c]entral, in our view, to the 
    
             present case is the fact that the subjects of the Policy are (1) children, who (2) 
    
             have been committed to the temporary custody of the State as schoolmaster."  Id. 
    
             As such, students "have a lesser expectation of privacy than members of the 
    
             population generally."  Id. at 657 (quoting T.L.O., 469 U.S. at 348 (Powell, J., 
    
             concurring)).  Student athletes have an even lower expectation of privacy 
    
             because, in addition to enjoying a lesser degree of physical privacy in athletic 
    
             locker rooms, the Court analogized student athletes to adults working in closely 
    
             regulated industries who "have reason to expect intrusions upon normal rights 
    
             and privileges, including privacy."  Id.(7)
    
                   The Court then considered the character of the particular intrusion 
    
             involved.  After concluding that the physical process by which urine was 
    
             collected for the drug testing was under conditions "nearly identical to those 
    
             typically encountered in public restrooms," id. at 658, and therefore relatively 
    
             unintrusive, the Court also examined whether the testing was unduly intrusive 
    
             because of the information it disclosed about the individual's body.  It 
    
             determined that it was minimally intrusive in that regard because the test only 
    
             revealed the existence of drugs, not medical or other physical conditions, the 
    
             tests were all standardized, and the information revealed was disclosed only to 
    
             those school personnel having a need to know, not to law enforcement or others 
    
             within the school community.  The Court also assumed that information about 
    
             prescription medications the student was compelled to reveal was kept 
    
             confidential.  Thus, the Court concluded the "invasion of privacy was not 
    
             significant."  Id. at 660.
    
                  Last, the Court examined the "nature and immediacy of the governmental 
    
             concern at issue."  Id.  It noted more generally the importance of deterring drug 
    
             use among schoolchildren, particularly given that the "[s]chool years are the time 
    
             when the physical, psychological, and addictive effects of drugs are most severe," 
    
             (7)     The Court cited Skinner, in which a factor favoring suspicionless drug 
             testing of railroad employees was the fact that such employees already worked in 
             "an industry that is regulated pervasively to ensure safety."  489 U.S. at 627.  
             
     
             and that "the effects of a drug-infested school are visited not just upon the users, 
    
             but upon the entire student body and faculty, as the educational process is 
    
             disrupted."  Id. at 661-62.  Additionally, the Court noted that the testing policy at 
             
             issue was not just directed at students in general, but, more narrowly, student 
    
             athletes "where the risk of immediate physical harm to the drug user or those 
    
             with whom he is playing is particularly high."  Id. at 662.  Moreover, the 
    
             "particular drugs screened by the District's Policy have been demonstrated to 
    
             pose substantial physical risks to athletes."  Id.
    
                  As to the immediacy of the District's concerns, the Court stated, "we could 
    
             not possibly find clearly erroneous the District Court's conclusion that `a large 
    
             segment of the student body, particularly those involved in interscholastic 
    
             athletics, was in a state of rebellion,' that `[d]isciplinary actions had reached 
    
             "epidemic proportions,"' and that `the rebellion was being fueled by alcohol and 
    
             drug abuse as well as by the student's misperceptions about the drug culture." 
    
             Id. at 662-63.  The Court characterized the problem as an "immediate crisis" of 
    
             greater magnitude than that involved in either Skinner or Von Raab.  And the 
    
             Court concluded the District's solution to that crisis?drug testing student 
    
             athletes?was self-evidently efficacious:  "a drug problem largely fueled by the 
    
             `role model' effect of athletes' drug use, and of particular danger to athletes, is 
    
             effectively addressed by making sure that athletes do not use drugs."  Id. at 663.
    
                  Accordingly, after carefully considering all the factors discussed above, the 
    
             Court upheld the Vernonia schools' drug testing policy.  It emphasized two 
    
             factors in particular:  that the testing policy "was undertaken in furtherance of the 
    
             government's responsibilities, under a public school system, as guardian and tutor
             
     
             of children entrusted to its care"; and that the district had demonstrated a severe 
    
             need for the testing.  Id. at 665.
    
                  Applying those factors to the Policy in this case, we reach a different 
    
             conclusion.  We first note that the evidence of drug use among those subject to 
    
             the Policy is far from the "epidemic" and "immediate crisis" faced by the 
    
             Vernonia schools and emphasized by the Supreme Court's opinion.  The district 
    
             court in this case admitted as much:  "[a]dmittedly the evidence in this case does 
    
             not show an epidemic of illegal drug use in the Tecumseh School District." 
    
             Earls, 115 F. Supp. 2d at 1285.  Rather, the evidence of actual drug usage, 
    
             particularly among the tested students, is minimal:  Dean Rogers, the president of 
    
             the school board, testified that in 1999, a member of FFA was found with drug 
    
             paraphernalia in his car.  Appellants' App. Vol. I at 120, 137-38.  She further 
    
             testified that in 1990 or 1991, a student apparently under the influence of some 
    
             substance was injured when a steer he was handling got loose, although it is 
    
             unclear from her testimony whether this occurred during an FFA activity.  Id. at 
    
             119-21.  Principal James Blue testified that in the "many" years he had been 
    
             principal of Tecumseh High School, there had been no alcohol or drug-related 
    
             injuries or deaths.  Id. at 162.  Ms. Rogers also testified that in 1997 or 1998, she 
    
             overheard a boy in FFA invite some other boys over to his house where "there 
    
             would be plenty of smokes."  Id. at 134.
    
    
     
                  Carolyn Daugherty, the vocal music teacher and choir director, testified 
    
             that she had never caught a choir member using illegal drugs, Appellants' App. 
    
             Vol. II at 286; that she has had students tell her they thought some other student 
    
             was using drugs, id. at 287; that she suspected some students were using some 
    
             substance because "appearance wise their eyes looked dilated [and] [t]hey looked 
    
             spaced out," id.; that she had referred one student to the office for suspected drug 
    
             use during her twenty-nine years of teaching, id. at 289; that she did not recall 
    
             ever telling the school board that choir members had a drug problem, id. at 290; 
    
             that a choir member was caught six or seven years previously bringing alcohol 
    
             concealed in a cough syrup bottle on a trip, id. at 292; and that, in her opinion, 
    
             most of her choir students do not use drugs.  Id. at 302.
    
                  Teacher Sheila Evans testified that she did not think that any of her 
    
             students in FHA who competed used drugs.  Appellants' App. Vol. III at 673. 
    
             Teacher Danny Sterling testified that during the preceding five years, he had 
    
             talked to the principal three to four times about some student in one of his classes 
    
             that he suspected was using drugs.  Id. at 711.  One time he "actually smelt the 
    
             aroma of pot."  Id. at 712.  He further testified that he estimates he sees ten 
    
             students per year whom he believes are on drugs.  None of these students 
    
             competed with FFA.  He testified that he believed that students in FFA were less 
    
             likely to use drugs than students who were not so involved.  Id. at 713.
    
    
     
                  Danny Jacobs, the assistant superintendent, testified that 243 students were 
    
             tested under the Policy during the 1998-99 school year, and of those students, 
    
             three tested positive, two high school students and one middle school student. 
    
             Appellants' App. Vol. II at 408-09.  He further testified that approximately 241 
    
             students were tested in the 1999-2000 school year, and one tested positive.  Id.  
    
             Principal James Blue testified that, with respect to the two high school students 
    
             who tested positive, one was involved in wrestling and FFA and one was involved 
    
             in baseball and FFA.  Appellants' App. Vol. III at 570.  Grant Gower testified 
    
             that the student who tested positive in the 1999-2000 year played softball.  Id. at 
    
             656-57.
    
                  In response to interrogatories, the District provided information that in the 
    
             1998-99 year, 208 students participated in FFA, 119 in FHA, 70 in Band, 14 in 
    
             Academic Team and 75 in Vocal Music.  Id. at 737.  In the first semester of the 
    
             1999-2000 school year, 100 participated in FFA, 63 in FHA, 67 in Band, 16 in 
    
             Academic Team and 65 in Vocal Music.  Id. at 737-38.(8)  Thus, in the 1998-99 
    
             year, of the 486 students who participated in the five listed extracurricular 
             
             activities, two students, both also athletes, tested positive.  And of the 311 
    
             students participating in extracurricular activities the first semester of the 1999-
    
             2000 year, only one student, apparently an athlete and not involved in any of the 
    
             listed extracurricular activities, tested positive.
    
                  The record also contains photocopies of disciplinary referrals at the high 
    
             school.  Some contain no date indicating the year in which the incident occurred. 
    
             Of the twenty incidents occurring over an unspecified period of time, thirteen 
    
             resulted from a drug dog "hitting" or showing an interest in the student, or his or 
    
             her vehicle or locker.  One involved possession of marijuana.  The remainder 
    
             involved possession of or suspected consumption of alcohol.  Id. at 633-51. 
    
             There is no evidence as to whether any of the students given these disciplinary 
    
             referrals were involved in extracurricular activities.  Similarly, in its response to 
    
             interrogatories, the District listed occasions when students received counseling 
    
             for use of drugs or talked to counselors concerning drug usage.  The 
    
             circumstances and details surrounding these incidents do not appear to have been 
    
             developed more fully with additional evidence, nor is there any indication that 
    
             any of the students, at least at the high school level, were involved in 
    
             extracurricular activities.
    
             (8)     These are figures for the high school only.  Figures for middle school 
             participation were also included.  In its response to interrogatories the District 
             also listed various incidents involving sixth, seventh and eighth grade students 
             and drugs.  However, virtually all the evidence presented in this case through 
             depositions related to the high school, where the plaintiffs were students.  The 
             district court's opinion likewise refers only to evidence involving the high school. 
              
             
     
                  In its yearly application for funds under the Safe and Drug-Free Schools 
    
             and Communities program, the District submitted a statement called an "analysis 
    
             of current use."  In the application for the 1995-96 year, the District stated, 
             
             "[t]he use of the surveys have provided us with information concerning alcohol as our 
    
             number one problem.  Our students express that the main use is alcohol on the 
    
             weekends.  We have not found other types of illegal or controlled substances to 
    
             be a major problem although they do exist."  Id. at 806.  Similarly, the 1996-97 
    
             application stated, "[t]he use of tobacco and alcohol continue to be our number 
    
             one problems.  Our students utilize that alcohol primarily on the weekends and 
    
             use tobacco, especially smokeless tobacco, on a more regular basis.  Other types 
    
             of drugs including, controlled dangerous substances, are present but have not 
    
             identified themselves as major problems at this time."  Id. at 809.  The 
    
             application for the 1998-99 year contained a virtually identical statement.  Id. at 
    
             813.  Mr. Jacobs testified that the forms contained accurate information. 
    
             Appellants' App. Vol. II at 366.
    
                  The District points to other instances of alleged drug usage to bolster its 
    
             argument that there was a serious drug problem at the Tecumseh schools.  Several 
    
             of these instances occurred in the early 1970's.  Many are based upon hearsay, or 
    
             are virtually anecdotal.  Except for the specific instances discussed above, none 
    
             relate to students who are involved in the extracurricular activities to which the 
    
             Policy applies.(9)
    
             (9)     For example, the District recites the following evidence of drug usage:
             
             1.  Fourteen instances of drug usage by District students known tothe President 
             of the District Board.
             2.  Injuries which have occurred to students and members of the 
             public by District students engaged in Competitive Activities under 
             the influence of drugs.
                                          . . . .
             
             6.  Students enrolled in classes associated with Competitive 
             Activities have been caught with or disciplined for drugs in the last 
             four years.
                                          . . . .
             Appellees' Brief in Chief at 5-6.  
             
                  Some of these assertions involve distortions of the record in this case.  For 
             instance, the "fourteen instances of drug usage" known to Dean Rogers include 
             the following:  in 1970, her daughter told her that an unidentified boy on the 
             school bus had offered her some pills, Appellants' App. Vol. II at 521; in 1978, 
             one of her son's unidentified friends on the football team left a bag with drug 
             paraphernalia in it at her house, id.; in 1979, her son told her of "parties" he went 
             to at which marijuana was smoked, Appellants' App. Vol. I at 127-28; in 1980, 
             "[o]ne of the boys that ran with [her] son" was stopped and marijuana was found 
             in his car, id. at 128-29; her daughter told her in 1972 or 1973 that the boyfriend 
             of the girl with whom she shared a locker sold drugs, id. at 117; sometime in the 
             middle 1980s a meter reader found some marijuana near the meter at what is now 
             a junior high school, Appellants' App. Vol. II at 524; in the 1980s her grandson 
             told her that an unidentified student had a marijuana cigarette at school, id. at 
             526; in the 1990s her grandson told her he attended a party and the girlfriend of a 
             friend found her mother's marijuana and passed it around, id. at 527; the 1998 
             incident discussed above in which she overheard a boy in FFA invite other boys 
             to a party at which "there would plenty of smokes," id. at 529; in the 1997-98 
             school year, her granddaughter told her that an unidentified boy "was bombed out 
             and the teacher ask[ed] him if he was all right," id. at 530; in the 1997-98 year, a 
             student not involved in any extracurricular activities was found to have marijuana 
             in his car, id. at 551; the 1999 incident discussed above in which an FFA student 
             was found with drug paraphernalia in his car.  Id. 
             
                  The reference to "injuries" to "students" and "members of the public" is to 
             the incident in 1990 or 1991 when a steer got loose from a student under the
             influence of some substance, injuring himself and one other person.  Id. at 476-
             77.
             
                  The record reference to the statement that "students enrolled in classes 
             associated with Competitive Activities have been caught with or disciplined for 
             drugs in the last four years" is a response to an interrogatory in which the District 
             stated that Principal Blue "can testify that students enrolled in FFA, FHA and 
             Athletics have been caught with drugs or disciplined for drugs."  Appellants' 
             App. Vol. III at 738.  As indicated above, however, Principal Blue actually 
             testified that, of the three high school students who tested positive under the 
             Policy, all three were athletes and two were involved in FFA.  
             
     
             
    
             
    
             
    
                  In sum, while there was clearly some drug use at the Tecumseh schools, 
    
             such use among students subject to the testing Policy was negligible.  It was 
    
             vastly different from the epidemic of drug use and discipline problems among the 
    
             very group subject to testing in Vernonia.  With that in mind, we balance the 
    
             privacy interests of the students against the District's interest in testing students 
    
             pursuant to the Policy.
    
             
    
                  I. Nature of Privacy Interest
    
                  As in Vernonia, we first consider the "nature of the privacy interest upon 
    
             which the search here at issue intrudes."  Vernonia, 515 U.S. at 654.  It is well 
    
             established that, while 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), 
             
             "students within the school environment have a lesser expectation of 
    
             privacy than members of the population generally."  T.L.O., 469 U.S. at 348 
    
             (Powell, J., concurring).  The Court in Vernonia found student athletes have an 
    
             even lesser expectation of privacy than other students, both because of a 
    
             perceived "`communal undress' inherent in athletic participation," Vernonia, 515 
    
             U.S. at 657 (quoting Schaill v. Tippecanoe County Sch. Corp., 864 F.2d 1309, 
    
             1318 (1988)), and because athletes, simply by participating on the team, 
    
             voluntarily subject themselves to increased supervision and additional 
    
             obligations.
    
                  The District argues that participants in the extracurricular activities subject 
    
             to testing under the Policy, like athletes, have a reduced expectation of privacy 
    
             because:  (1) they voluntarily participate; (2) they occasionally travel out of town 
    
             on trips where they must sleep together in communal settings and use communal 
    
             bathrooms; and (3) they agree to abide by "the higher degree of academic and 
    
             out-of-school rules and regulations of both the District and the OSSAA." 
    
             Appellees' Brief in Chief at 17.  While it is probably true that the degree of 
    
             "communal undress" associated with most of the extracurricular activities in this 
    
             case is different from the level of "communal undress" among athletes envisioned 
    
             by the Supreme Court in Vernonia, we decline to give that difference, whatever it 
    
    
     
             may be, much weight in our analysis.  We doubt that the Court intends that the 
    
             level of privacy expectation depends upon the degree to which particular students, 
             
             or groups of students, dress or shower together or, on occasion, share 
    
             sleeping or bathroom facilities while on occasional out-of-town trips.(10)
    
                  More significant to us is the fact that, like athletes, students participating 
    
             in other extracurricular activities voluntarily submit themselves to at least some 
    
             additional requirements and obligations.(11)  We examine first whether the 
    
             voluntariness of the participation in the activity reduces a student's legitimate 
    
             expectation of privacy while participating in that activity.
    
                  We do not believe that voluntary participation in an activity, without more, 
    
             should reduce a student's expectation of privacy in his or her body.  Members of 
    
             our society voluntarily engage in a variety of activities every day, and do not 
    
             thereby suffer a reduction in their constitutional rights.  As another court recently 
    
             stated, "we disagree [with the view] that just by exercising a privilege in any 
    
             activity that is part of the educational process, a student's privacy interests are 
    
             lessened and that a school district can, without more, condition participation in 
    
             that activity on agreeing to testing just because the activities are optional."  
             
             Theodore v. Del. Valley Sch. Dist., 761 A.2d 652, 660 (Pa. Commw. Ct. 2000). 
    
             Moreover, while participation in extracurricular activities is voluntary, such 
    
             participation has become an integral part of the educational experience for most 
    
             students.  The Supreme Court recently cautioned against "minimiz[ing] the 
    
             importance to many students of attending and participating in extracurricular 
    
             activities as part of a complete educational experience."  Santa Fe Indep. Sch. 
    
             Dist. v. Doe, 120 S. Ct. 2266, 2280 (2000); see also Trinidad Sch. Dist. No. 1 v. 
    
             Lopez, 963 P.2d 1095, 1109 (Colo. 1998) ("the reality for many students who 
    
             wish to pursue post-secondary educational training and/or professional vocations 
    
             requiring experience garnered only by participating in extracurricular activities is 
    
             that they must engage in such activities . . . . [I]nvolvement in a school's 
    
             extracurricular offerings is a vital adjunct to the educational experience.").  Thus, 
    
             the voluntariness of the participation, without more, does not reduce a student's 
    
             expectation of privacy.
    
                  However, there are other aspects of participating in extracurricular 
    
             activities which do legitimately lower a student's expectation of privacy.  While 
    
             students participating in non-athletic extracurricular activities need not obtain 
    
             pre-participation physicals or insurance, as athletes must, they do, like athletes, 
    
             (10)     Moreover, there was evidence in this case that not all athletes "shower[] 
             and chang[e]" together after each event.  Vernonia, 515 U.S. at 657.  See 
             Appellants' App. Vol. II at 380. 
             (11)     The District Superintendent, Tom Wilsie, submitted an affidavit in which 
             he stated that students wishing to participate in OSSAA sanctioned activities, like 
             the extracurricular activities at issue in this case, "must meet scholastic standards 
             in order to be eligible to participate."  Wilsie Aff. at 5, Appellants' App. Vol. I 
             at 78.
             
     
             agree to follow the directives and adhere to the rules set out by the coach or other 
    
             director of the activity.  This inevitably requires that their personal freedom to 
    
             conduct themselves is, in some small way, constrained at least some of the time.  
             
             We therefore conclude that, like athletes, participants in other extracurricular 
    
             activities have a somewhat lesser privacy expectation than other students.
    
             
    
                  II.  Character of Intrusion
    
                  We turn next to "the character of the intrusion that is complained of." 
    
             Vernonia, 515 U.S. at 658.  Because the manner of testing, the information 
    
             obtained, and the use to which that information is put are, in this case, virtually 
    
             identical to the testing process in Vernonia, we reach the same conclusion as did 
    
             the Supreme Court:  "the invasion of privacy was not significant."  Id. at 660.
    
             
    
                  III.  Nature and Immediacy of Concern and Efficacy of Solution
    
                  The final factor we consider is "the nature and immediacy of the 
    
             governmental concern at issue here, and the efficacy of this means for meeting 
    
             it."  Id.  This factor tips the balancing analysis decidedly in favor of the 
    
             plaintiffs.    As the Court acknowledged in Vernonia, there can be no doubt that 
    
             the District's interest in deterring drug use among students is very important, 
    
             "perhaps compelling."  Id. at 661.  However, in addition to noting the general 
    
             danger to children of drug abuse, the Court in Vernonia emphasized the particular 
    
             danger to athletes caused by drug usage:
    
                  the risk of immediate physical harm to the drug user or those with 
                  whom he is playing his sport is particularly high.  Apart from 
                  psychological effects, which include impairment of judgment, slow
             
     
                  reaction time, and a lessening of the perception of pain, the 
                  particular drugs screened by the District's Policy have been 
                  demonstrated to pose substantial physical risks to athletes.
             
             Id. at 662.  The District argues that students engaged in extracurricular activities 
    
             are equally at risk of physical harm, both to themselves and others, because, for 
    
             example, band members perform routines with heavy instruments and FFA 
    
             members at times wrestle large animals.  Furthermore, the District argues, 
    
             participants in competitive extracurricular activities, like athletes, often practice 
    
             or prepare for competitions after school and on weekends, and travel on 
    
             occasional overnight trips, where they are subject to less supervision than regular 
    
             students.
    
                  This argument proves both too much and too little.  While there may 
    
             indeed be some extracurricular activities that involve a safety issue comparable to 
    
             that of athletes, there are other students involved in extracurricular activities and 
    
             therefore subject to the Policy who can hardly be considered a safety risk.  It is 
    
             difficult to imagine how participants in vocal choir, or the academic team, or 
    
             even the FHA are in physical danger if they compete in those activities while 
    
             using drugs, any more than any student is at risk simply from using drugs.  On 
    
             the other hand, there are students who are not subject to the testing Policy but 
    
             who engage in activities in connection with school, such as working with shop 
    
             equipment or laboratories, which involve a measurable safety risk.  Thus, safety 
    
             cannot be the sole justification for testing all students in competitive
             
     
             extracurricular activities, because the Policy, from a safety perspective, tests both 
    
             too many students and too few.  In essence, it too often simply tests the wrong 
    
             students.(12)
    
                  Perhaps recognizing this dilemma, the District relies more heavily on the 
    
             fact that all extracurricular students are subject to less supervision than students 
    
             in classrooms when they are staying after school to meet and/or practice, and 
    
             when they are traveling off campus to compete.  However, if this provides the 
    
             justification for testing, then again there is an imperfect match between the need 
    
             to test and the group tested.  Students who do not participate in any 
    
             extracurricular activities are, at times, less supervised than they are in the 
    
             classroom?when they are in the hallways between classes, at lunch, immediately 
    
             before and after school while they are entering and leaving school premises.
    
                  Moreover, Ms. Rogers testified that there are other student organizations 
    
             and groups which take field trips, meet after school, and otherwise engage in 
    
             precisely the same kinds of less supervised activities as those in the 
    
             extracurricular activities subject to drug testing under the Policy.  Appellants' 
    
             App. Vol. II at 480-82, 560-61.  The District admitted in a response to an
             
    
    
             (12)     To the extent one could argue that the safety issue here is the health care 
             risk of addiction or physical harm from the use of drugs, then the logical solution 
             is to test all students.  The fact that the District only tests a select group of 
             students-those participating in extracurricular activities-indicates that its testing 
             Policy is not motivated simply by health care concerns.  
             
     
             interrogatory that other groups, not subject to the Policy, have traveled overnight. 
    
             Appellants' App. Vol. III at 739.  Accordingly, neither a concern for safety nor a 
    
             concern about the degree of supervision provides a sufficient reason for testing 
    
             the particular students whom the District chose to test under the Policy.
    
                  Additionally, given the paucity of evidence of an actual drug abuse 
    
             problem among those subject to the Policy, the immediacy of the District's 
    
             concern is greatly diminished.  And, without a demonstrated drug abuse problem 
    
             among the group being tested, the efficacy of the District's solution to its 
    
             perceived problem is similarly greatly diminished.  While the Court in Vernonia 
    
             had no trouble identifying the efficacy of a drug testing policy for athletes when 
    
             the athletes were at the heart of the drug problem, we see little efficacy in a drug 
    
             testing policy which tests students among whom there is no measurable drug 
    
             problem.  See Trinidad Sch. Dist. No. 1, 963 P.2d at 1110 (holding that the 
    
             school district failed to demonstrate the efficacy of its testing policy because it 
    
             "swept within its reach students participating in an extracurricular activity who 
    
             were not demonstrated to play a role in promoting drugs and for whom there was 
    
             no demonstrated risk of physical injury").
    
                  In sum, applying the factors identified by the Supreme Court in Vernonia, 
    
             we conclude that the testing Policy is unconstitutional.  We do not suggest that a 
    
             school must wait until it can identify a drug abuse problem of epidemic 
    
             proportions before it may drug test groups of its students.  Nor do we declare any
             
     
             bright line mark concerning the magnitude at which a drug problem becomes 
    
             severe enough to warrant a suspicionless drug testing policy.  We leave that to 
    
             each school district.  However, any district seeking to impose a random 
    
             suspicionless drug testing policy as a condition to participation in a school 
    
             activity must demonstrate that there is some identifiable drug abuse problem 
    
             among a sufficient number of those subject to the testing, such that testing that 
    
             group of students will actually redress its drug problem.(13)  "[S]pecial needs must 
    
             rest on demonstrated realities."  United Teachers of New Orleans v. Orleans 
    
             Parish Sch. Bd., 142 F.3d 853, 857 (5th Cir. 1998).  Unless a district is required 
    
             to demonstrate such a problem, there is no limit on what students a school may 
    
             randomly and without suspicion test.  Without any limitation, schools could test 
    
             all of their students simply as a condition of attending school.  The District 
             
             admits it could not test its entire student body and we doubt very much that the 
    
             Supreme Court would permit such broad testing were the issue presented to it.
    
                  In reaching this result, we realize that we are disagreeing with two of our 
    
             fellow circuits.(14)  However, there are other courts with which we are in 
    
              
    
             agreement.  This issue is obviously a difficult one with which courts will 
    
             continue to grapple.
    
             
    
                                         CONCLUSION
    
                  For the foregoing reasons, we REVERSE and REMAND this matter to the 
    
             district court for further proceedings consistent herewith.
             (13)     As the court in Theodore put it:
             
             While the purposes articulated set forth a governmental interest 
             supporting a generalized drug and alcohol testing program, no reason 
             is given for a special need to test only those students who engage in 
             optional activities . . . more than the general student population.  To 
             carry out the health care analogy, it would be as if the School 
             District was offering a polio vaccine only to those students engaged 
             in extracurricular activities . . . without expressing a need as to why 
             those students are more likely to contract polio or more likely to 
             cause the spread of disease than any other selective group of 
             students.
             
             Theodore, 761 A.2d at 661. 
             (14)     In Todd v. Rush County Schs., 133 F.3d 984 (7th Cir. 1998), the Seventh 
             Circuit upheld the random suspicionless drug testing of high school students 
             participating in extracurricular activities and driving to and from school.  The 
             court did so, however, with a scant and conclusory analysis:  "we find that the 
             reasoning compelling drug testing of athletes also applies to testing of students 
             involved in extracurricular activities.  Certainly successful extracurricular 
             activities require healthy students."  Id. at 986.  The court also noted that 
             participation in extracurricular activities is a privilege in which students have 
             voluntarily chosen to participate.  Rehearing en banc was denied, with written 
             dissents by four judges.  Todd v. Rush County Schs., 139 F.3d 571 (7th Cir. 
             1998).
             
                  The Seventh Circuit then held unconstitutional a policy of drug testing any 
             student who was suspended or violated specified rules in Willis v. Anderson 
             Comm. Sch. Corp., 158 F.3d 415 (7th Cir. 1998).  Rather than making a 
             conclusory determination, as in Todd, the Willis court carefully surveyed the 
             Supreme Court case law and each factor set forth in Vernonia. 
             
                  Most recently, in Joy v. Penn-Harris Madison Sch. Corp., 212 F.3d 1052 
             (7th Cir. 2000), the Seventh Circuit again upheld the random suspicionless drug 
             testing of students involved in extracurricular activities and driving to and from 
             school, but it did so clearly only because it was bound under the doctrines of 
             stare decisis and precedent to follow Todd.  The court made it clear that, were it 
             not so bound, it would find the policy unconstitutional under a careful and 
             thorough application of the Vernonia factors. 
             
                  The Eighth Circuit, in a decision subsequently vacated as moot, also 
             upheld a suspicionless drug testing policy applicable to students participating in 
             extracurricular activities.  Miller v. Wilkes, 172 F.3d 574 (8th Cir. 1999).  In 
             applying the Vernonia factors, the court was untroubled by the fact that the 
             school had presented no evidence of an actual drug problem.  The court simply
             took judicial notice of the seriousness of drug and alcohol abuse in public 
             schools.
             
                  By contrast, the Colorado Supreme Court held unconstitutional the 
             suspicionless drug testing of all participants in the marching band.  Trinidad Sch. 
             Dist. No. 1 v. Lopez, 963 P.2d 1095 (Colo. 1998).  After applying all the 
             Vernonia factors, the court concluded that "the nature of the privacy interest 
             invaded was different from that of the student athletes in Vernonia" and, although 
             the district established it had a drug abuse problem, "the means chosen to deal 
             with that problem were too broad."  Id. at 1110; see also Linke v. Northwestern 
             Sch. Corp., 734 N.E. 2d 252 (Ind. Ct. App. 2000) (holding unconstitutional under 
             the Indiana Constitution a suspicionless drug testing policy applicable to athletes 
             and others involved in certain extracurricular activities); Theodore v. Del. Valley 
             Sch. Dist., 761 A.2d 652 (Pa. Commw. Ct. 2000) (holding unconstitutional a 
             suspicionless drug testing policy applicable to those participating in 
             extracurricular activities and driving to school).
             
                  Two district court cases within the Fifth Circuit have addressed this issue. 
             In Brooks v. East Chambers Consol. Indep. Sch. Dist., 730 F. Supp. 759 (S.D. 
             Tex. 1989), aff'd, 930 F.2d 915 (5th Cir. 1991), a pre-Vernonia case, the court 
             held unconstitutional suspicionless drug testing of students wishing to participate 
             in extracurricular activities.  The court held the testing was intrusive, there was 
             no evidence of a drug problem or greater safety risk among those subject to the 
             test, and the policy was "not likely to accomplish its ostensible goals."  Id. at 
             765.  The Fifth Circuit affirmed that decision without an opinion.  
             
                  The Fifth Circuit will have an opportunity to revisit this issue, because 
             another Texas district court has recently held unconstitutional the random 
             suspicionless drug testing of all students participating in extracurricular 
             activities.  Gardner v. Tulia Indep. Sch. Dist., No. 2:97-CV-020-J (N.D. Tex. 
             filed Dec. 7, 2000).  The school district has appealed the case to the Fifth 
             Circuit.  The court in Gardner, after noting that there was no evidence of a drug 
             problem among students in general at the Tulia schools or among those 
             participating in extracurricular activities and therefore subject to testing, held that 
             Vernonia "was limited to random drug testing of the student athletes."  Slip op. at 
             8; see also Tannahill v. Lockney Indep. Sch. Dist., No. 5:00-CV-0073-C (N.D. 
             Tex. filed March 1, 2001) (holding unconstitutional a drug testing policy
             applicable to all students).
             
     
             00-6128, Earls v. Board of Education of Tecumseh Public School District
             EBEL, Circuit Judge, dissenting
             
             
                  I respectfully dissent from the panel's decision in this difficult case. 
    
             Although I agree with many of the standards articulated by the majority in its 
    
             opinion, I am unconvinced that the majority has actually followed those standards 
    
             in reaching its final conclusion.
    
             
    
                  1.  Special Needs Analysis
    
                  I agree with the majority that, under Vernonia School District v. Acton, 
    
             515 U.S. 646 (1995), a public school district need not demonstrate a 
    
             particularized "special need" to randomly test students engaged in extracurricular 
    
             activities for illegal drug use.(1)  The "special needs" test, which is used in non-
    
             school settings to justify suspicionless searches, is dispensed with (or deemed 
    
             satisfied) in a school setting because of the following, uniquely school-related 
    
             considerations.
    
                  First, drugs are a particularly serious problem in our public schools, not 
    
             just because of alarming rates of drug usage among school-age children,(2) but also
             
    
    
             (1)      The Vernonia Court did not even discuss the special needs doctrine 
             before moving ahead to the balancing portion of its analysis.
             (2)      One study indicates that, of children between the ages of twelve and 
             seventeen, 18.7 percent report having used marijuana or hashish in their lifetimes. 
             In addition, 2.4 percent report having used cocaine, 5.7 percent report having 
             used hallucinogens, and 9.1 percent admit to having used inhalants.  See
             Substance Abuse and Mental Health Services Administration, 1999 National 
             Household Survey on Drug Abuse: Appendix G (Table G.7), available at 
             http://www.samhsa.gov/oas/NHSDA/1999/Appendixg.htm (last visited March 8, 
             2001).  Furthermore, 10.9 percent of children age twelve to seventeen reported 
             current (within thirty days of being interviewed) use of illegal drugs in 1999.  See 
             Substance Abuse and Mental Health Services Administration, 1999 National 
             Household Survey on Drug Abuse: Chapter 2, National Estimates of Substance 
             Abuse, available at http://www.samhsa.gov/oas/NHSDA/1999/Chapter2.htm (last 
             visited March 8, 2001).
                  More alarming still are the statistics regarding first time drug use among 
             children between the ages of twelve and seventeen.  Of the 2.39 million people 
             who reported having tried marijuana for the first time in 1998, 1.56 million were 
             between the ages of twelve and seventeen.  Of the 934,000 people who first used 
             cocaine in 1998, 315,000 were between the ages of twelve and seventeen.  See 
             Substance Abuse and Mental Health Services Administration, 1999 National 
             Household Survey on Drug Abuse: Appendix G (Tables G.49, G.50), available at 
             http://www.samhsa.gov/oas/NHSDA/1999/Appendixg.htm (last visited March 8, 
             2001).
             
     
             both because young people are especially susceptible to peer pressure 
    
             encouraging the use of drugs and because of the especially virulent health damage 
    
             caused by drug use among school-age children.  See Vernonia, 515 U.S. at 661 
    
             ("School years are the time when the physical, psychological and addictive 
    
             effects of drugs are most severe. `Maturing nervous systems are more critically 
    
             impaired by intoxicants than mature ones are; childhood losses in learning are 
    
             lifelong and profound'; `children grow chemically dependent more quickly than 
    
             adults, and their record of recovery is depressingly poor.'" (citation omitted)).
    
                   Second, the Supreme Court in New Jersey v. T.L.O., 469 U.S. 325 (1985), 
    
             held that both search warrants and a requirement of probable cause are 
    
             impractical in the school setting.  See 469 U.S. at 340.  Further, in Vernonia the 
    
             Court went on to state that any suspicion-based testing changes the relationship 
    
             between students and teachers from one of trust and cooperation to one of 
    
             distrust and adversarial interactions. See 515 U.S. at 664 (noting that suspicion-
    
             based drug testing would "add[] to the ever-expanding diversionary duties of 
    
             schoolteachers" by forcing them to "spot[] and bring[] to account drug abuse, a 
    
             task for which they are ill prepared, and which is not readily compatible with 
    
             their vocation"). 
    
                  Third, in the closed environment of a public school, drug use by some 
    
             students interferes with the rights of other students to learn and grow in the 
    
             educational environment.  See id. at 662 ("[O]f course the effects of a drug-
    
             infested school are visited not just upon the users, but upon the entire student 
    
             body and faculty, as the educational process is disrupted."). Also, drug use may 
    
             spread in such a setting, in a manner akin to other contagious diseases for which 
    
             school districts have always had the authority to test and to control.
    
                  Fourth, and perhaps most important, is the Supreme Court's recognition in 
    
             Vernonia that public schools vest in the State a responsibility to protect the 
    
             children entrusted to its care from numerous social ills, including the use of 
    
             illegal drugs.  See id. ("[T]he necessity for the State to act is magnified by the
             
     
             fact that this evil is being visited not just upon individuals at large, but upon 
    
             children for whom it has undertaken a special responsibility of care and 
    
             direction.").  In this regard, a school district has an almost in loco parentis 
    
             relationship with its students, which vests in the school district special 
    
             responsibilities for, and concomitant authority over, those children.  See id. at 
    
             654-55.  
    
                  Accordingly, I agree with the majority that the public school district in this 
    
             case need not demonstrate, as a threshold matter, a special need to adopt the 
    
             challenged drug testing Policy before we may proceed to the required Vernonia 
    
             balancing analysis.(3)  Accord Miller v. Wilkes, 172 F.3d 574, 578 (8th Cir. 1999) 
    
             ("The Supreme Court has held that the public school environment provides the requisite 
             
             `special needs' so that a school district may dispense with those Fourth 
    
             Amendment protections [of probable cause and warrants issued by a neutral 
    
             magistrate]."), vacated as moot, 172 F.3d at 582.
    
                  Notwithstanding the majority's statement that no special need for random, 
    
             suspicionless drug testing must be demonstrated by the school district in this 
    
             case, the majority appears to reimpose a special needs requirement toward the 
    
             end of its opinion.  
    
                  The majority writes:
    
                  [A]ny district seeking to impose a random suspicionless drug testing 
                  policy as a condition to participation in a school activity must 
                  demonstrate that there is some identifiable drug abuse problem 
                  among a sufficient number of those subject to testing, such that 
                  testing that group of students will actually redress its drug problem. 
                  "[S]pecial needs must rest on demonstrated realities."
    
             See ante at 33 (quoting United Teachers of New Orleans v. Orleans Parish Sch. 
    
             Bd., 142 F.3d 853, 857 (5th Cir. 1998)).  This is similar to language used by 
    
             another panel of this court in a case arising in a non-school setting, 19 Solid 
    
             Waste Department Mechanics v. City of Albuquerque, 156 F.3d 1068 (10th Cir. 
    
             1998) ("19 Solid Waste Mechanics"), where we discussed the special needs 
    
             analysis that must take place when reviewing random, suspicionless drug testing 
    
             of certain city employees.  There, this court stated that the special needs test asks 
    
             whether the drug testing policy "was adopted in response to a documented drug 
    
             abuse problem or whether drug use among the target group would pose a serious
             (3)      As one commentator has noted:
             
             [T]he Court's student search decisions [in T.L.O. and Vernonia] 
             establish constitutional standards that are explicitly tailored to take 
             account of the school context.  More importantly, the Court justified 
             the standards and results as necessary to protect the educational 
             process.  The Court in both T.L.O. and [Vernonia] thus upheld the 
             searches not on the ground that maintaining order is an inherently 
             important goal, but rather on the theory that some semblance of 
             order is a necessary means to achieve the "primary" goal of schools: 
             educating students.
             
             James E. Ryan, The Supreme Court and Public Schools, 86 Va. L. Rev. 1335, 
             1363 (2000).  Accordingly, "the Court has tailored the constitutional standards 
             ... to fit the school context, and it has generally done so in a way that lends 
             more authority to the government (here, school officials) and less protection to 
             individuals (here, students) than exists outside the school context."  Id. at 1369.
             
     
             danger to the public."  Id. at 1073. That threshold inquiry is inappropriate in a 
    
             school setting, however, where the majority has correctly observed that a showing 
    
             of special need is unnecessary pursuant to the Supreme Court's holding in 
    
             Vernonia.
    
                  I believe that requiring the school district in this case to make a threshold 
    
             showing of special need, based upon proven drug use by a "sufficient number of 
    
             those subject to testing," before it may implement a policy of random drug testing 
    
             of students engaged in extracurricular activities mandates a more detailed 
    
             demonstration than was ever required in either Vernonia or 19 Solid Waste 
    
             Mechanics.  
    
                  In Vernonia, the Supreme Court held that the respondent school district had 
    
             justified its policy of randomly testing student athletes for drug use even though 
    
             there was little actual evidence in the record that those students tested were, in 
    
             fact, the students most likely to use drugs.  Despite the district court's rhetoric to 
    
             the contrary, see, e.g., Vernonia, 515 U.S. at 662-63 (noting the district court's 
    
             findings that "a large segment of the student body, particularly those involved in 
    
             interscholastic athletics, was in a state of rebellion" and "that the rebellion was 
    
             being fueled by alcohol and drug abuse as well as by the student[s'] 
    
             misperceptions about the drug culture"), the evidence in Vernonia of drug use by 
    
             student athletes, or even by other students attending either the school in question 
    
             or other schools in the respondent school district, was quite limited.  The
             
     
             evidence of drug use among student athletes was confined to the smell of 
    
             marijuana detected on one road trip by the school wrestling coach, see id. at 679 
    
             (O'Connor, J., dissenting), one "severe sternum injury suffered by a wrestler, and 
    
             various omissions of safety procedures and misexecutions by football players, all 
    
             attributable in [an expert witness's] belief to the effects of drug use," id. at 649. 
    
             Thus, there was no real demonstration in the Vernonia record, other than the one-
    
             time smell of marijuana and one expert's opinion, that the student athletes subject 
    
             to the drug testing policy were frequent drug users or had exhibited a propensity 
    
             toward drug use.  The evidence of drug use among the student body in general 
    
             was similarly attenuated, as it consisted of only: (1) a few instances of observed 
    
             drug use by students; (2) student absenteeism in one peer group due to its desire 
    
             to use drugs during the school day; (3) admissions by "several students" that they 
    
             had used drugs; (4) one student's "obviously inebriated" appearance one day at 
    
             school; and (5) one student's statement that he was "high on life" while dancing 
    
             and singing in the back of a classroom.  See id. at 679 (O'Connor, J., dissenting). 
    
             Finally, in regard to the three grade schools subject to the drug testing policy,
             
             (4) there was "virtually no evidence in the record" of student drug use.  See id. at 
    
             684 (O'Connor, J., dissenting).  At one grade school, for example, the only 
    
             evidence of drug use among the student body was an unsupported "`guarantee' by 
    
             the . . . grade school principal that `our problems we've had in `88 and `89 didn't 
    
             start at the high school level.  They started at the elementary school.'" Id. 
    
             (O'Connor, J., dissenting) (concluding, "Perhaps there is a drug problem at the 
    
             grade school, but one would not know it from this record").  
    
                  Thus, on facts not much more compelling than those presented in this case, 
    
             the Supreme Court found that the school district in Vernonia had justified its 
    
             drug testing policy for all students who were enrolled in the seventh through 
    
             twelfth grades in any school within the district and who were engaged in sports-
    
             related, voluntary extracurricular activities.
    
                  Furthermore, in the non-school case of 19 Solid Waste Mechanics, we held 
    
             that the district had established an adequate interest in testing mechanics 
    
             employed by the city for drug use, even though it had not demonstrated any 
    
             nexus between the employees subject to the test and any known drug problem.
             (4)         The respondent school district in Vernonia operated four schools: one 
             high school and three grade schools.  See Vernonia, 515 U.S. at 648.  The three 
             grade schools apparently encompassed the first through eighth grades, while the 
             high school apparently encompassed the ninth through twelfth grades.  See id. at 
             684 (O'Connor, J., dissenting).  All students enrolled at the high school who 
             engaged in student athletics were subject to the challenged drug testing policy. 
             See id. at 685 (O'Connor, J., dissenting).  As to the grade schools, it appears that
             only the seventh and eighth grade student athletes were subjected to the drug 
             testing requirement.  See id. at 684 (O'Connor, J., dissenting) (noting that the 
             Vernonia opinion upholds drug testing of seventh and eighth graders enrolled at 
             the grade schools).  The named plaintiff in Vernonia, James Acton, was in the 
             seventh grade when he initiated the lawsuit challenging the school district's drug 
             testing requirement as it restricted his joining the Washington Grade School 
             football team.  See id.at 651.
             
     
             See 156 F.3d at 1074 (accepting the city's asserted rationale for adopting a 
    
             mandatory drug testing program, i.e., "public safety and employee health," even 
    
             though there was absolutely no demonstrated history of drug use by the group 
    
             subject to testing).  To the extent that we accepted a public safety rationale to 
    
             justify the drug testing policy in 19 Solid Waste Mechanics, see id. (noting that 
    
             the tested employees worked around potentially dangerous machines and repaired 
    
             city vehicles that would later be "released back onto city streets"), the asserted 
    
             public safety concern in that case was certainly no more compelling or immediate 
    
             than the safety and well-being of students enrolled in our public schools.  And 
    
             yet, despite the relative weakness of the city's "public safety and employee 
    
             health" concerns, we held that an adequate justification for testing had been 
    
             established in 19 Solid Waste Mechanics, and we struck down the drug testing 
    
             program only because the tested employees received advance notice of the tests, 
    
             which were administered just once every four years, such that the drug testing 
    
             "lack[ed] a real capacity to address drug use in the workplace."  Id.  Thus, it was 
    
             the lack of efficacy in the solution, rather than the lack of a demonstrated drug 
    
             problem or immediate public safety concern, that caused the drug testing policy 
    
             to be invalidated in 19 Solid Waste Mechanics.
    
                  Here, by reimposing a special needs requirement at the end of its opinion, 
    
             and thereby requiring a school district to demonstrate an "identifiable drug abuse 
    
             problem among a sufficient number of those subject to testing," the majority has
             
     
             both reneged on its earlier holding that a school district need not demonstrate a 
    
             special need for random, suspicionless drug testing in the public school context 
    
             and required more of the school district in this case than was ever required in 
    
             either Vernonia or 19 Solid Waste Mechanics.  
    
                  For that reason, I must disagree with the majority's opinion on that issue.
    
             
    
                  2.   Balancing test
    
                  I also disagree with the majority's ultimate application of Vernonia's 
    
             balancing test, by which the school district's Policy must be weighed.  The 
    
             Vernonia balancing test requires that we weigh the nature of the students' privacy 
    
             interest and the character of the intrusion on that interest, on the one hand, 
    
             against the nature and immediacy of the school district's concern and the efficacy 
    
             of the proposed solution, on the other hand.  While I agree completely with the 
    
             majority's discussion of several factors to be considered, and agree at least in 
    
             part with its discussion of other factors, I nonetheless think the majority 
    
             ultimately strikes the wrong balance.
    
             
    
                       a.   Nature of the Students' Privacy Interest and Character of the 
                            Intrusion 
    
                  The Supreme Court has stated that "students within the school environment 
    
             have a lesser expectation of privacy than members of the population generally."
             
     
             T.L.O., 469 U.S. at 348 (Powell, J., concurring).  I agree with the majority that 
    
             the privacy rights of the students subject to testing under the Policy in this case 
    
             are further diminished, as compared to the privacy rights of students in general, 
    
             due to the students' voluntary participation in extracurricular activities.  See ante 
    
             at 28 ("We therefore conclude that, like athletes, participants in other 
    
             extracurricular activities have a somewhat lesser privacy expectation than other 
    
             students.").  Further, I agree with the majority that the character of the intrusion 
    
             at issue in this case is "virtually identical to the testing process in Vernonia," 
    
             about which the Supreme Court stated: "the invasion of privacy [is] not 
    
             significant."   
    
                  I diverge with the majority only where, once again, I believe it has not 
    
             actually followed the articulated conclusions and analysis it has set forth for 
    
             itself.  
    
                  Despite having reached the conclusion that the students subject to testing 
    
             under the Policy have reduced privacy expectations and that the intrusion itself is 
    
             "not significant," the majority nevertheless places what appears to be substantial 
    
             weight upon those factors when performing the final balancing test under 
    
             Vernonia.  That is, while the majority denigrates the school district's interests to 
    
             be weighed on the other side of the scale, and perhaps rightly so, the majority 
    
             appears to forget its earlier conclusion that there is just not much for the school 
    
             district's interests to be weighed against.  In my opinion, having determined both
             
     
             that the students' privacy expectations are diminished and that the intrusion itself 
    
             is minimal, the majority may find that the "balancing analysis [tips] decidedly in 
    
             favor of the plaintiffs," see ante at 29, only if the factors favoring drug testing, 
    
             which must be weighed on the other side of the scale under Vernonia, are truly 
    
             insignificant.  That is clearly not the case.
    
             
    
                       b.   Nature and Immediacy of the School District's Concern, and 
                            Efficacy of the Drug Testing Policy 
    
                  As the Supreme Court stated in Vernonia, "That the nature of the concern 
    
             is important ? indeed, perhaps compelling ? can hardly be doubted." See 515 
    
             U.S. at 661.  It is difficult to imagine an interest more compelling than stemming 
    
             the tide of illegal drug use by young women and men before they subject 
    
             themselves, and our society, to substantial risk and heartache.  The public schools 
    
             have an obligation to supervise and control the students under their care.  See id. 
    
             at 655 ("[A] proper educational environment requires close supervision of 
    
             schoolchildren, as well as the enforcement of rules against conduct that would be 
    
             perfectly permissible if undertaken by an adult.") (alteration in original).  As 
    
             noted by the Vernonia Court, this obligation imposes upon school officials a duty 
    
             to protect the children under their care from evils that may befall them: 
    
                  While we do not, of course, suggest that public schools as a general 
                  matter have such a degree of control over children as to give rise to a 
                  constitutional duty to protect, we have acknowledged that for many 
                  purposes school authorities ac[t] in loco parentis, with the power and 
                  duty to inculcate the habits and manners of civility.
    
    
     
             Id. (citations and quotations omitted) (alternation in original).  Discouraging drug 
    
             use among impressionable children is without question an integral part of a 
    
             public school's duty to "inculcate the habits and manners of civility" in the 
    
             students entrusted to their care.
    
                  The immediacy of the school district's concern is, as noted by the majority, 
    
             the weakest part of the school district's case.  In Vernonia, the Court gauged the 
    
             immediacy of the respondent school district's concern by discussing what it 
    
             characterized as a serious drug problem evidenced in the district in question. See 
    
             515 U.S. at 662-63 (noting that, based upon the district court's factual findings 
    
             regarding drug use in the school district, there was "an immediate crisis" 
    
             justifying random, suspicionless drug testing of student athletes).  The majority in 
    
             this case seems to have interpreted the immediacy discussion in Vernonia to state 
    
             that a drug problem is not "immediate" if it has not reached "crisis" levels, as is 
    
             evidenced by the majority's statement that a school district must demonstrate 
    
             "some identifiable drug abuse problem among a sufficient number" of students 
    
             before it may implement a random drug testing policy.  I disagree.  While it may 
    
             be true that under Vernonia there can be no drug testing of students where there 
    
             is no evidence of drug use by the student body, Vernonia does not require that a 
    
             school district allow illegal drugs to gain a stronghold among its schoolchildren 
    
             before it may take steps to eliminate them through random drug testing.  Indeed, 
    
             as discussed earlier, see discussion supra at 8-9, in Vernonia itself the actual
             
     
             evidence of drug use by students in the respondent school district did not 
    
             demonstrate that the school district had been overtaken by a drug problem of 
    
             overwhelming proportions.  Illegal drugs extract a tremendous toll on their 
    
             victims, and are nearly impossible to eliminate once they have garnered a 
    
             foothold in our communities, schools and homes.(5)  To the extent that it is 
    
             possible to prevent the irreparable harm attendant to illegal drug use through the 
    
             diligent efforts of officials in our public schools, we should allow them to try.
    
                  Finally, in regard to the efficacy of the program, we have received briefs 
    
             from amicus curiae presenting arguments on both sides of this issue.  It is clear 
    
             from these briefs that the efficacy of random, suspicionless drug testing in the 
    
             public schools may legitimately be debated by knowledgeable sources.  What is 
    
             even more clear from this robust scholarly and practical debate, however, is that 
    
             the efficacy question is not one that ought to be decided by members of the 
    
             federal judiciary, who are so far removed from public school students and the 
    
             officials who supervise them as to make their determinations speculative in the 
    
             extreme.  I would therefore defer to the judgment of local school boards, which 
    
             are far better positioned (and more accountable) than federal judges to decide the
             
    
    
    
             (5)      The intractability of drugs in our society is compellingly and realistically 
             depicted in the film Traffic (USA Films 2000), a current Academy Award 
             nominee for Best Motion Picture.  
             
     
             type of drug testing policy that will best serve their need to protect children 
    
             entrusted to their care.
    
                  I find this to be a difficult case, and acknowledge that the balancing of the 
    
             Vernonia factors is far from easy.  Given the weight that I believe is properly 
    
             afforded to each factor set forth in Vernonia, however, I would find that the 
    
             Policy survives the constitutional balancing test and should therefore be upheld. 
    
             
    
                  3.   Other Issues
    
                  There are a few more things that must be said of my decision to dissent 
    
             from the majority opinion.  
    
                  First, I believe the majority places too little weight on the fact that the 
    
             testing here is limited to extracurricular activities, where the students have 
    
             voluntarily submitted themselves to additional supervision and regulation. 
    
             Participation in extracurricular activities is a privilege, not a right, see Albach v. 
    
             Odle, 531 F.2d 983, 984-85 (10th Cir. 1976), and consequently schools are 
    
             allowed to impose additional burdens on their participants, see id. at 985 (holding 
    
             that the "supervision and regulation of high school athletic programs remain 
    
             within the discretion of appropriate state boards"). See also Todd v. Rush County 
    
             Schs., 133 F.3d 984, 986 (7th Cir. 1998).  Additional conditions on student 
    
             participation in extracurricular activities have often been upheld by this and other 
    
             courts, and I see no reason why a drug test that we have deemed "not
             
     
             significant[ly]" invasive should be treated any differently.  Furthermore, the 
    
             extracurricular activities included within the purview of the challenged Policy 
    
             involve travel and after-school activities where adult supervision is necessarily 
    
             diminished as compared to the level of supervision involved in the average 
    
             classroom.  This reduced level of supervision in the context of extracurricular 
    
             activities could well lead to the type of experimentation in drug use that this 
    
             Policy is expressly designed to prevent.  
    
                  The balancing might very well have come out differently if the drug testing 
    
             Policy at issue in this case had been imposed upon the entire student body as a 
    
             condition of enrollment in the respondent school district.  See discussion infra at 
    
             20-21.  In this case, however, the only students subject to testing are those who 
    
             have chosen to engage in extracurricular activities which pose a potentially 
    
             enhanced risk of drug abuse due to their decreased levels of supervision and 
    
             which are privileges, not rights, to the affected students.  In my view, this factor 
    
             is insufficiently weighted by the majority in its opinion.
    
                  Second, the majority also errs, in my opinion, by arguing that the Policy is 
    
             constitutionally suspect because it is both underinclusive and overinclusive.  See 
    
             ante at 30-31 (noting that the Policy "tests both too many students and too few" 
    
             because it does not test all students who engage in travel or potentially dangerous 
    
             school-related activities, or all students involved in extracurricular activities that 
    
             are difficult to supervise, but does test some extracurricular activity students who
             
     
             do not engage in travel or dangerous school-sponsored activities and who have no 
    
             demonstrated history of, or propensity toward, drug abuse).  It is true that not all 
    
             students who travel as part of their extracurricular involvements are currently 
    
             subjected to random drug testing under the Policy.  Given the majority's concern 
    
             about the Policy's constitutionality as it is currently formulated, however, it 
    
             could hardly be considered "more" constitutional by the inclusion of more 
    
             students into its testing scheme.  In any event, we have never stated that a policy 
    
             aimed at correcting a social ill need solve the entire problem in one fell swoop; in 
    
             many cases it may be more prudent and efficacious to address social problems 
    
             one step at a time, so that each step may be reviewed and adapted as necessary. 
    
             See Williamson v. Lee Optical of Oklahoma, Inc., 348 U.S. 483, 489 (1955) 
    
             ("[T]he reform may take one step at a time, addressing itself to the phase of the 
    
             problem which seems most acute to the legislative mind."). 
    
                  I believe the majority's concern about overinclusiveness is similarly 
    
             misplaced under the Supreme Court's decision in Vernonia.  As previously 
    
             discussed, despite the expansive language in the lower court opinion in Vernonia, 
    
             the actual evidence in that case did not show that all student athletes subjected to 
    
             random drug testing had demonstrated a significantly higher propensity for drug 
    
             use than any other children in the district or, for that matter, than the students 
    
             subjected to random drug testing in this case.  Indeed, Vernonia upheld a policy 
    
             of drug testing that included selected grade school students involved in athletics,
             
     
             even though there was essentially no evidence that the tested grade school 
    
             children used drugs at all.  Any argument that the Policy is overinclusive is thus 
    
             limited by the Supreme Court's recognition that the policy in Vernonia passed 
    
             constitutional muster despite its testing of students who had no demonstrated 
    
             history of drug abuse.
    
                  Although I do not disagree that issues of overinclusiveness or 
    
             underinclusivenes are relevant inquiries, the majority seems to require a nearly 
    
             perfect match between the problem and the solution, akin to the narrowly tailored 
    
             requirement utilized in strict scrutiny analysis.  This is not required under 
    
             Vernonia.  See Vernonia, 515 U.S. at 661-65 (applying a less rigorous five-factor 
    
             balancing test rather than a strict scrutiny analysis).  Here, we are dealing not 
    
             with a fundamental right but with the conditions a school district constitutionally 
    
             may impose upon students who voluntarily engage in a privileged activity.  As 
    
             such, there is no requirement that the school district prove the Policy is narrowly 
    
             tailored before it may withstand constitutional scrutiny.  Accord Vernonia, 515 
    
             U.S. at 663 (rejecting plaintiffs' argument that the school district must adopt the 
    
             "least intrusive" means possible, i.e., suspicion-based testing, to detect student 
    
             drug use).  
    
                  This is not to say that all public school students can or should be randomly 
    
             tested for drug use.  While the Supreme Court in San Antonio Independent School 
    
             District v. Rodriguez, 411 U.S. 1, 37 (1973), held that education is not a
             
     
             fundamental right, it recognized in Goss v. Lopez, 419 U.S. 565, 574 (1975), that 
    
             a student's entitlement to an elementary and secondary public education is a 
    
             property interest which is constitutionally protected by the Due Process Clause.  I 
    
             agree with Justice Ginsburg's statement in concurrence in Vernonia that she 
    
             understood the Court's opinion "as reserving the question whether the District, on 
    
             no more than the showing made here, constitutionally could impose routine drug 
    
             testing . . . on all students required to attend school."  See 515 U.S. at 666 
    
             (Ginsburg, J., concurring). Vernonia allows drug testing only of those students 
    
             who voluntarily engage in extracurricular activities, and thereby agree to be 
    
             bound by additional rules and regulations to which the average, non-involved 
    
             student need not adhere.  In my view, a random, suspicionless drug testing policy 
    
             that tested all public school students as a requirement of their continued 
    
             attendance in the public schools would present a potentially intolerable burden on 
    
             those students' right to a free public education and would likely run afoul of the 
    
             Constitution.  But that is decidedly not the case with which we are presented 
    
             today.
    
                  Third, this type of search is quite dissimilar to the general searches, 
    
             typically related to criminal proceedings, about which the Framers were most 
    
             concerned when they drafted the Fourth Amendment. The cases and authorities 
    
             cited by Justice O'Connor in her Vernonia dissent to support the argument that 
    
             the Framers "most strongly opposed . . .  general searches ? that is, searches by
             
     
             general warrant, by writ of assistance, by broad statute, or by any other similar 
    
             authority," see 515 U.S. at 669 (O'Connor, J., dissenting), deal primarily with 
    
             searches conducted in the criminal context, and not with searches conducted as a 
    
             condition precedent to engaging in a voluntary, discretionary activity which 
    
             carries no criminal consequences.  Indeed, Justice O'Connor noted that "several 
    
             evenhanded blanket searches, including some that are more than minimally 
    
             intrusive," have been upheld by the Supreme Court where the searches took place 
    
             not in the criminal context but in closely regulated industries or, more important 
    
             to this analysis, "in unique contexts such as prisons."  See id. at 673 (O'Connor, 
    
             J., dissenting).  It is undeniably true that state officials have considerably greater 
    
             latitude in a prison setting than in a public school setting.  It is nevertheless also 
    
             true that public schools, somewhat like prisons and other highly regulated 
    
             settings, present supervisory officials with unique circumstances and 
    
             responsibilities that necessarily result in diminished Fourth Amendment rights for 
    
             the people entrusted to their care. See id. at 656 ("Fourth Amendment rights, no 
    
             less than First and Fourteenth Amendment rights, are different in public schools 
    
             than elsewhere; the `reasonableness' inquiry cannot disregard the schools' 
    
             custodial and tutelary responsibility for children.").  
    
                  Here, the information collected during the drug test is shared only with 
    
             selected school officials on a need-to-know basis, and is never turned over to law 
    
             enforcement officers or used to justify academic sanctions against students who
             
     
             test positive for illegal drug use.  Further, if a student does not want to submit to 
    
             a drug test, the school district cannot compel submission under the challenged 
    
             Policy.  Any student may refuse to submit to a drug test.  The only consequence 
    
             of that decision is the student's subsequent ineligibility to participate in a 
    
             voluntary extracurricular activity because of his or her failure to satisfy one of 
    
             the preconditions to participation in that activity.  
    
                  Under these circumstances, where we are dealing with a population that 
    
             has voluntarily subjected itself to testing and the test results are never used for 
    
             criminal or disciplinary purposes, I do not believe the minimal privacy invasion 
    
             involved presents the kind of general search that the Framers intended to prohibit 
    
             when drafting the Fourth Amendment.
    
                  Fourth, I note, as does the majority, that the decision to strike down this 
    
             Policy as unconstitutional creates a split among the federal circuit courts of 
    
             appeals on an issue of substantial constitutional significance.  In Todd v. Rush 
    
             County Schools, 133 F.3d 984, 986-87 (7th Cir. 1998), the Seventh Circuit 
    
             upheld against constitutional challenge a drug testing policy very similar to the 
    
             policy at issue in this case.  Rehearing en banc was denied in that case, despite 
    
             the written dissents of four judges.  See Todd v. Rush County Schs., 139 F.3d 
    
             571 (7th Cir. 1998).  It is true, as the majority states, see ante at 34 n.14, that the 
    
             Todd decision was subsequently criticized by another panel of the Seventh 
    
             Circuit.  See Joy v. Penn-Harris Madison Sch. Corp., 212 F.3d 1052 (7th Cir.
             
     
             2000).  However, the Todd decision nevertheless remains the law in the Seventh 
    
             Circuit.  The Eighth Circuit upheld a similar drug testing policy in Miller v. 
    
             Wilkes, 172 F.3d 574 (8th Cir. 1999), although that decision was later vacated as 
    
             moot.  The Fifth Circuit is likely to address this question soon, as a district court 
    
             opinion invalidating a school district's random, suspicionless drug testing policy 
    
             as it applied to students engaged in non-athletic extracurricular activities has 
    
             apparently been appealed to that court.  See Gardner v. Tulia Indep. Sch. Dist., 
    
             No. 2:97-CV-020-J, slip op. at 8 (N.D. Tex. Dec. 7, 2000) (stating that Vernonia 
    
             "was limited to random drug testing of the student athletes").  
    
                  For these reasons, I respectfully dissent and encourage the school district 
    
             to seek an en banc rehearing by this court so that we may reconsider our 
    
             decision.  Failing that, perhaps the Supreme Court will grant a writ of certiorari 
    
             to resolve the split among the circuits that we have today created on the 
    
             important constitutional issue presented in this case.
    
             
    
    

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