In Bd. of Educ. v. Earls, 536 U.S. 822 , 830-34 (2002), the Court held that a public schools policy of requiring drug testing of all students participating in extracurricular activities fell within the special needs exception. A students privacy interest is limited in a public school environment . . . . Id. at 830. Because the school conducted the test with many procedural safeguards and used the results only in connection with permitting the student to participate in extracurricular activities, the Court held that, given the minimally intrusive nature of the sample collection and the limited uses to which the test results are put, we conclude that the invasion of students privacy is not significant. Id. at 834. Finally, the Court considered the schools strong interest in preventing drug use by schoolchildren, especially because of specific evidence of drug use at the school in question. Id.