Doe v. Renfrow

Doe v. Renfrow (N.D.Ind. 1979) 475 F.Supp. 1012, upheld an exploratory search with narcotics dogs in a public school setting, "an area where courts have not granted full application of the Fourth Amendment's protections." ( Id ., at p. 1020.) The case was a civil action. In upholding the search the court stressed the in loco parentis status of the school officials, the extensive drug activity discovered at the school in the days immediately before the search and the agreement with the police officer handling the dog that no arrests would occur as a result of finding any drugs upon students. There was no independent information by school authorities who used detector dogs to sniff out narcotics on person of students in a public school; the court held it was "a minimal intrusion at best and not so serious as to invoke the protections of the Fourth Amendment." (P. 1020.)