People v. Bobby B.

Citations: 172 Cal. App. 3d 377; 218 Cal. Rptr. 253; 1985 Cal. App. LEXIS 2529Docket: B009267

Court: California Court of Appeal; September 23, 1985; California; State Appellate Court

SummaryOriginalCytator Case TreatmentBackward CitatorAnalysis

EnglishEspañolSimplified EnglishEspañol Fácil

An appeal was filed by 17-year-old Bobby B. challenging the denial of his motion to suppress evidence under Welfare and Institutions Code section 700.1. The appeal follows a juvenile court's decision where Bobby was placed on probation after being adjudicated as a ward of the court for his involvement in juvenile activities on September 24, 1984. On October 21, 1984, Carlos Martinez, the administrative boys' dean at Lincoln High School, found Bobby and another boy in a restroom without proper authorization during class hours. When asked to present a pass, neither boy complied, raising Martinez's suspicion, especially given prior knowledge of narcotics activity in that area. Bobby's inability to produce a pass and his evasive behavior prompted Martinez to search him, leading to the discovery of two cigarettes resembling marijuana and a bindle containing cocaine in Bobby's wallet. Martinez seized these items and contacted the police, who later arrested Bobby. The appeal does not contest the probation conditions imposed by the court.

Bobby contends that the motion to suppress evidence was improperly denied, arguing there was insufficient probable cause for the search conducted in the bathroom at Lincoln High School. The legal framework for assessing the search's validity is drawn from New Jersey v. T.L.O., which established that searches in schools do not require strict adherence to probable cause but must instead be reasonable under the circumstances. The reasonableness of a search involves two inquiries: whether the search was justified at its inception and whether its scope was reasonably related to the circumstances that justified the initial interference. A search is justified when there are reasonable grounds to suspect it will uncover evidence of a violation of law or school rules, and its scope must not be excessively intrusive considering the student's age and the nature of the suspected infraction.

The standard aims to balance the need for school order with the privacy rights of students, allowing teachers and administrators to act sensibly without needing in-depth legal knowledge of probable cause. Following the precedent set in In re Lance W., it is established that the right to contest the admissibility of evidence from searches of minors must be grounded in federal law, not California state law. The case further establishes that Dean Martinez's actions were justified based on testimony regarding ongoing narcotic issues in the school's restrooms, coupled with the minor's nervous demeanor and presence in the restroom without a pass, affirming reasonable suspicion.

A school dean, tasked with monitoring drug use, conducted a search of a student found in a restricted area without a pass, which led to the discovery of concealed marijuana and cocaine. The investigation began with the dean's proper presence in the restroom, where he asked reasonable questions to ascertain potential drug activities. The court evaluated whether the search was appropriately scoped to the circumstances that justified it. It concluded that the dean's actions were reasonable, given the context of suspected drug use in an area where students were prohibited. The search was found to be neither excessive nor intrusive, thereby upholding the dean’s reasonable suspicion and method of search. Consequently, the motion to suppress the evidence obtained was denied, affirming the grant of probation to the appellant. The ruling was supported by a previous court case, In re Christopher W. (1973). A minority opinion from the Supreme Court acknowledged the Fourth Amendment protections for minors in schools but argued that the search of a purse was intrusive without probable cause, echoing the appellant's claims.