In New Jersey v. T. L. O. (1985) 469 U.S. 325, the court recognized the legitimate needs of schools to maintain a safe environment. The court there, dealing with an individualized search of a student who had been seen smoking in the restroom, found that the requirement for probable cause as applied to law enforcement would be inappropriate for the school environment. The court declared that reasonable suspicion on the part of administrators was sufficient to meet the demands of the Fourth Amendment. The court recognized the applicability of the "special needs" exception to the general principles of the Fourth Amendment jurisprudence applied to the public school environment. (469 U.S. at p. 333.)