Safford Unified School District #1 v. Redding

Middle-school vice principal Kerry Wilson (defendant) discovered that students in the school were giving out prescription-strength ibuprofen and over-the-counter naproxen. These pills were common pain relievers. One student told Wilson that she had received the pills from 13-year-old Savanna Redding (plaintiff). Wilson confronted Redding, and Redding denied having any knowledge of the pills. Wilson searched Redding’s backpack and did not find any more pills. Wilson then had a female administrative assistant (defendant) take Redding into the office of the female school nurse (defendant) to perform a strip search. Redding was directed to undress down to her underwear and then pull her bra and underwear away from her body and shake them. This exposed her breasts and pelvic area to the two school employees. Redding described this as embarrassing, frightening, and humiliating. No pills were discovered. Redding sued the school district (defendant), Wilson, the administrative assistant, and the school nurse (collectively, the school parties) for violating her Fourth Amendment right to be free from unreasonable government searches. The district court granted the school parties’ motion for summary judgment and dismissed the claim. Redding appealed the decision. In an en banc decision, the United States Court of Appeals for the Ninth Circuit reversed the district court’s decision, finding that the search of Redding violated her Fourth Amendment rights but that only the school district and Wilson could be liable for the violation. The United States Supreme Court granted certiorari.