Ziegler v. Martin Cnty. Sch. Bd., No. 15-11441 (11th Cir. 2016)Annotate this Case
Plaintiffs filed suit alleging that defendants violated students' constitutional rights when they detained the students for breathalyzer tests prior to entering their Junior/Senior Prom. The district court granted summary judgment for defendants. The court concluded that plaintiffs have not established an actual or reasonable expectation of privacy in the party bus, which they had abandoned once they had exited for the Prom; the bus driver had apparent authority to consent to search the party bus; and therefore, the search of the party bus did not violate plaintiffs' Fourth Amendment rights. The court also concluded that the initial waiting period for the breathalyzer mouthpieces and a trained individual to administer the breathalyzer tests was reasonable, because it was necessary for the testing; detaining a student after he or she was found to be alcohol free was not “reasonably related” to the reason for the detention “in the first place” of determining if the student passengers on the party bus had been drinking; the individual school defendants are entitled to qualified immunity because there was no binding clearly established law at the time; and claims against the remaining defendants have been abandoned or have no merit. The court rejected plaintiffs' remaining claims. Because plaintiffs have not established that they should succeed on any of their allegations concerning their Fourth, First, and Fourteenth Amendment claims, the court affirmed the judgment.