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Drug Testing and Searches

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									Drugs in New Zealand Schools – Drug Testing, Searches and Student’s Legal Rights Children’s Issues Centre – Joined Up Services Conference 27 June 2003

Introduction The legal issues surrounding drugs and schools have been topical in New Zealand for some time now. Involvement with drugs constitutes the largest category of student suspensions in New Zealand schools, noted as constituting 30 percent of all suspensions in the Ministry of Education’s most recent periodic report on stand-downs, suspensions and exclusions. 1471 students were suspended in 2002 [1] for drugs and substance abuse. This figure constitutes a decrease in drug-related suspensions from the previous report of April 2002 (from 32%), so it will be interesting to see whether the figure continues to decrease in the next report. However, the decrease is not substantial and it would be fair to conclude that drug-related suspensions remain at a concerning level. Drug-related incidents in schools usually entail an interface between a number of agencies – the school, the Police, community health services (such as CADS), Strengthening Families Services for example – that are all focused on the child or children in question, albeit from varying roles and ethical perspectives. This paper attempts to focus on the processes these agencies undertake in these matters, and the manner in which they impact on the children affected by them. I will also canvas some of the civil liberties issues that arise when students are involved in drug allegations at school, such as drug testing and searching of students, issue which remain of constant relevance to young people who attend school. A Children’s Rights Perspective There is no question that drugs pose a significant threat to the well-being of our young people. Schools, the police, drug education agencies and other relevant agencies, all share a common interest in protecting young people from the destructive impact of drugs and reducing any harm or damage that has accumulated. On occasion, however, it would appear that the child’s legal rights and interests often get lost in the scramble for punishment, rehabilitation and accountability of the child concerned. Legally, children’s rights are central to issues relating to drugs in schools. Drug testing and searches involve intrusions on the civil liberties of the children concerned, and therefore it is important that these procedures are undertaken with due consideration of these rights.

Providing an overarching legal framework is the United Nations Convention on the Rights of the Child. New Zealand has not incorporated the provisions of the Convention into a statutory enactment, but its state agencies are obliged, by virtue of New Zealand’s ratification of the Convention, to give effect to its provisions. It follows that Article 3.1 of the Convention provides that the best interests of the child must be given primary consideration by a school. Thus, the most important consideration for a school dealing with a drug incident involving its students must not be the school’s reputation or the importance of “sending a message” to the community or the students, but rather whether its decision making is in line with the student’s best interests. For example, a school Board of Trustees determining a drug-related suspension of a student, must consider whether subjecting a student to a degrading and intrusive procedure such as urinalysis is truly in the students best interests. The Convention also provides more specific guidance. Article 19 provides that countries must protect children from all forms of maltreatment. Article 37 similarly requires that no child be subjected to inhuman or degrading treatment. This article also provides a guarantee against arbitrary detention. Also, if the child is detained, he or she must be treated with humanity and respect for the inherent dignity of the human person. Article 28 mandates that school discipline be administered consistently with the child’s human dignity. These issues are all central to the way drug incidents are handled at school. The legal rights and interests of children enshrined in the Convention provide a common ground from which a cohesive joined-up services approach, between relevant agencies, can be derived. It is important to note that this is an area that is not regulated by prescriptive legislation. Schools, for example, clearly do not have express legal authority to undertake drug searching and testing procedures on their students. However, within the legal vacuum that is the education jurisdiction, these processes occur, according to my anecdotal experience, fairly frequently. Against this context, utilisation of a children’s rights perspective, which uses the Convention as a starting point, may reduce the risk of the child’s civil liberties being infringed and could offer a more holistic, [2] constructive way of ensuring that the best interests of the child are protected.

AUTHORITY OF SCHOOLS UNDER THE EDUCATION ACT 1989 Extent of Managerial Authority of Principals and Boards Sections 72, 75 and 76 of the Education Act 1989 give the Principal and Board of a state or integrated school very wide latitude to direct the control and management of the school. Nonetheless, the Act makes very clear that this power is subordinate to the “general law” of New Zealand as well as any

other statutory enactment. Thus, a school may not adopt or enforce any policy contrary to laws such as the New Zealand Bill of Rights Act 1990, the Privacy Act 1993, the common law, or New Zealand’s obligations under the U.N. Convention on the Rights of the Child. These laws confer on all students a set of rights and freedoms, which the school cannot undermine. Managerial and Disciplinary Jurisdiction The authority of the school is also limited to matters which reasonably relate to the control or management of the school. To that end, if a school were to carry out a drug testing program on a student, for example, it would need to establish that the drug use occurred on school property, in school time, or, if outside the school premises and hours, during circumstances related to the affairs of the school, such as a school trip, school weekend sport or attendance on the school bus. This [3] jurisdictional approach is clearly supported by guidelines issued by the Ministry of Education . The limits of a school’s jurisdiction and its means of sanctioning drug use often converge, particularly in relationship to its drug testing policies. Often a positive result from a drug test will not disclose when the consumption of the drug occurred. After all, a positive result can mean that the student consumed the drug nearly a month prior to the test. If that consumption took place at a Saturdaynight party with friends, the school would not technically be able to assert jurisdiction over the student and therefore should not legally be able to discipline a student for a positive test result in such a situation. However, in the reality of a school Board’s determination of the fate of a student suspended for alleged involvement with drugs, questions of jurisdiction are often brushed over as being mere technicalities. The condition of drug testing in consideration for reinstatement to school is, to the writer’s eyes, as much an expression of control and deterrence as it is focused on the student’s educational situation or personal context which may have led to alleged drug use. School drug policies The vast majority of schools have a drug policy – according to the June 2002 Education Review Office report on Drug Education in Schools, 98% of secondary schools claimed to have implemented [4] a drug education policy. However, schools vary widely in their approach to this issue, some favour an education-prevention approach; others favour deterrence (which may involve random drug testing or mandatory exclusion.) Some schools deal with these matters in conjunction with the police (through “rubicon” agreements) or health organizations (such as CADS or Odyssey House); others prefer to deal with these issues in isolation of external agencies. Notwithstanding the wholesale adoption of drug education policies by schools indicated by the ERO

report, there is little prescriptive guidance in terms of how such policies should be implemented and, when necessary, policed. In 2000 the Ministry of Education published Drug Education: A Guide for Principal’s and Boards of Trustees. The Guidelines offer a range of options designed to keep a student in school. It would be fair to say that they promote education and rehabilitation over deterrence and punishment. However, they fail to prescribe any standardised sets of procedures. For example, on the issue of drug testing, the Guidelines merely advise that a school seek legal advice before implementing a testing policy or requiring testing of an individual student. Rightly or wrongly, [5] the school is left to make such a decision at their sole discretion. This lack of formal guidance, I believe, explains the inconsistency that exists in the way different schools deal with drug incidents. Where at one school a student may be excluded for allegedly smoking cannabis during school hours, at another a student will be reinstated with conditions to attend drug counselling for the same offence. While one can understand the need to allow Boards to make decisions free from too much external interference, all students should expect to be treated with a degree of equity within the state education system. Compounding this problem of inconsistency is the lack of data available on the frequency of drug testing and drug searches within schools. Neither ERO, the Ministry of Education nor the Police were able to provide our office with any data as to the frequency of police drug searches in schools in response to a request for such data under the Official Information Act. This makes it very difficult to measure trends in the use of such procedures in schools beyond anecdotal experience. Procedures for Sanctioning Drug Use at School Suspensions The most common manner in which a school sanctions a student’s alleged involvement with drugs is through suspension, the most serious statutory power available to a principal to deal with incidents of misconduct. This is not suprising given the serious, criminal nature of illicit drug activity. It is clearly not something that a school administration can take lightly. The Principal The principal has the sole legal authority to stand-down or suspend a student (section 14(1) of the EA89. Not surprisingly, most students who have been accused of having some kind of involvement with drugs or alcohol at school find themselves stood-down or suspended, usually under the head of “gross misconduct” (section 14(1)(a)), defined by the High Court as acts of a “striking, reprehensible” nature. The decision whether to stand-down or suspend a student under section 14 is left to the complete discretion of the principal. However, it is important to note that suspension should not be considered an automatic response to a drug incident at school. The High Court has made it clear that the discretion to suspend should not be

fettered by preconceived policy considerations or a perceived necessity to maintain discipline (D v M & The Board of Trustees of Auckland Grammar School, High Court Auckland [1998] M 477/97 per Smellie J). Predetermination or a bias towards pre-determination is an invalid approach to finding gross misconduct. Despite this, some schools have adopted written polices where drug use or a positive drug test result are deemed to constitute automatic grounds for suspension. The Board Whilst a stood-down student only misses school for a finite period of time (up to 5 days) the future of a suspended student is determined by the Board of Trustees Disciplinary Sub-Committee of the a suspension meeting. The Board is granted quasi-judicial powers to make such a determination under section 13 of the EA89. An important component of these powers is the Board’s obligation to make its decision, like a Court of Law, in accordance with the principles of natural justice. Suspension Meetings Suspension meetings are run in a similar manner to proceedings before an adversarial tribunal. The principal’s role equates to that of a prosecutor, and he or she accordingly submits their case against the student by way of an incident report. This report, along with all other relevant information, must be disclosed to the student’s family at least 48 hours before the meeting (Education Stand Down, Suspension, Exclusion and Expulsion Rules 1999). The student and their family are permitted to bring along any advocates or support persons they feel necessary to support them at the meeting. This is usually a good idea, as students and their families can find these meetings very traumatic. After hearing both sides, the Board then makes its decision (usually adjourning to make its decision in private). It has three choices available to it, pursuant to sections 15 (for under 16 year olds) and 17 (for 16 year olds and over) of EA89.    Lift the suspension and reinstate the student to school with or without conditions Extend the students suspension with conditions for a reasonable period Exclude (if the student is under 16) or expel (if student is aged 16 or older) the student.

In making its decision, the Board must consider all options available to it. The High Court found in D v M that failure to give due consideration to lifting a suspension subject to conditions, would invalidate a decision to exclude. This is at odds with the de facto polices of many schools that drug use automatically validates exclusion or expulsion, which clearly breaches a Boards obligations under [6] section 13 of the Education Act. Suspension Hearings and External Agencies Suspension meetings are not particularly well suited to a joined-up services approach. This is largely

due to the structure of the meetings and the judicial nature of the Board’s decision-making powers. Decisions regarding a suspended student’s future are made in private after consideration of respective submissions on behalf of the student and the school. Problems can occur where a Board requires that the student meet certain conditions in order to be reinstated to school. The most common conditions with drug-related suspensions are drug counselling and drug testing, processes which both necessitate the involvement of external agencies, namely drug education agencies (such as CADS) and physicians and ESL. Sometimes these conditions do not correlate with the practices of the agencies referred to in such conditions. For example a Board may order that a student attend a certain number of counselling sessions with a drug counsellor without first having gathered from the service any indication of what they consider to be an appropriate course of counselling. The disparity between the Board’s expectations and the nature of the agencies service can, on occasion, break the review process down and lead to the student unnecessarily missing out in school in matters where there attendance relies on completion of the Boards conditions. Alternative Procedures to Suspension Restorative Justice Some Auckland schools have trialled restorative justice forums as an alternative to EA89 suspension procedures. Restorative justice dispute resolution is used predominantly in the youth justice and care and protection jurisdictions (under the Children, Young Persons and their Families Act 1989) in the form of Family Group Conferences. As a disciplinary procedure, restorative justice is probably better suited to a joined-up services approach than suspension hearings, as it involves the equitable input of all parties; the school, the student, the police, the drug counsellors and so forth. The resolution of a restorative justice forum is reliant on the collaborative agreement of all the parties, as opposed to the directive, quasi-judicial decision-making powers of a Board of Trustees. The process allows each party to explain their position and wishes, remorse or recommendations without the need to present them as pleadings (as is virtually the case in suspension meetings). It also ensures that the student, and the student’s family, has adequate input into the decision-making process and is not unduly coerced into consenting to onerous conditions such as drug testing. Restorative justice conferencing, in the form of Family Group Conferences, is a compulsory process [7] within the youth justice jurisdiction pursuant to the Children Young Persons and their Families Act (CYPF Act) A young person who has been caught using or dealing drugs will generally have their case resolved at FGC, where they are usually diverted from conviction subject to meeting a list of conditions. In other words, they are given a second chance. The CYPF Act recognizes that it is not in the interests of a young person to bear the burden of a criminal record for the rest of their lives as a result of offending that occurred as a result of juvenile behaviour. It is galling that students who are

found to have drugs at school face a far more punitive outcome (such as exclusion from school) under the school disciplinary procedure than the justice system. Police and School Alternative Actions Plans (Rubicon Agreements) This process is sometimes used in matters where the police have been called in by the school in relation to a drug incident. It is a good example of a formalised, co-ordinated procedure between school and the police for the purpose of dealing with a student who has been alleged to be involved with drugs at the school. In this respect it is an example of joined-up services in action. It is also analogous to police diversion as practiced in the youth justice jurisdiction. The student who has been accused of involvement of drugs at school is required to sign a written agreement with the Police and the school that requires them to undergo the following conditions:     Random drug testing Participation in a drug education “package” directed by the school Counselling with school counsellors Restrictions on the student’s movements during lunch breaks.

The agreement stays active for a duration agreed to by the parties, subject to a minimum period of one term. Failure to comply with this agreement can lead to the student being prosecuted by the police and placed before the school board of trustees for determination of their future. The rubicon concept is not without its merit, in that it offers an alternative disciplinary process to the student concerned, one that initially avoids the prospect of suspension or criminal charges. It also allows the matter to have a degree of police input into the investigation processes, which can be favourable to the student’s interests as the police have higher duties of care towards a young person during questioning (under section 215 of the CYPF Act) than a school staff member. The police also have more expertise in considering evidence and assessing liability than a school staff member. However, there could be legal problems associated with rubicon agreements as they appear to by-pass both the education and youth justice jurisdictions, while attempting to hold the student in question accountable to both. Rubicon agreements also appear to require that the student undertake onerous, intrusive conditions, such as random drug testing, without any legislative authority to do so, other than the student’s consent. Specifically, it circumvents both the Board’s decision-making authority under sections 13, 15 and 17 of the Education Act 1989; and the youth justice provisions of the CYPF Act, which provides for formal police warnings and cautions (sections 209-213) and stipulates that proceedings against the young person must not be held without the appointment of a Youthjustice Co-ordinator and a Family Group Conference (section 245). There are also possible questions concerning the validity of such an agreement on a minor,

particularly given the nature of the conditions in the example given. Rubicon agreements do not appear to involve negotiation or discussion as to terms and conditions and are different from restorative justice resolutions in that the agreement has not been procured through a meeting chaired by an independent co-ordinator. They are presented to the student in a “take it or leave it” fashion, which does not leave much room to consider any complex background issues that may be relevant. CIVIL LIBERTIES ISSUES I will now turn briefly to some of the civil liberties issues that arise out of the legal minefield that [8] surrounds the whole topic of drugs in schools. Schools are clearly subject to the New Zealand Bill of Rights Act 1990 (NZBORA), via section 3(b), as they perform a public function and exercise authority under the Education Act 1989. It is also arguable that private schools are also subject to the NZBORA as they registered under the Education Act, perform a public function in administering the national curriculum, and receive government funding to do so. In addition, the broad powers conferred upon a school’s Board and principal under sections 72, 75 and 76 of the Education Act 1989, for the purposes of management and control of the school, are expressly subject to the general law of New Zealand, which includes the NZBORA. This means that a school is unable to legally invoke any policy or procedure that contravenes the rights contained in the NZBORA, as they cannot rely on a section 4 “out”. In addition, it is strongly arguable that a school would not be able to limit a student’s NZBORA rights by way of section 5, as the school powers under the Education Act are expressly subordinate to the rights and freedoms contained within the NZBORA. In this respect schools have a particularly strong statutory responsibility to act in compliance with the NZBORA, this being in a much more express responsibility than accorded to many other state agencies. This implies that schools are not in a very strong legal position to implement procedures that may infringe upon the rights and freedoms of their students. Searches Drug incidents in schools commonly involve a search by staff or police at some stage. Section 21 of the NZBORA prohibits unreasonable search and seizure. There has been much case law development in this area, mostly concerning searches by Police. The most significant recent legal development was the case of R v Shaheed (2002) 2 NZLR 377 (CA). In this case the Court of Appeal established a test of proportionality, being that he Court should determine whether or not the search in question was unreasonable per the NZBORA, and, if so, whether the breach of rights was proportionately outweighs the evidence sought to be admitted. In another recent decision, R v Maihi (2002) CA181/02, the Court of Appeal “clarified” what constitutes a “reasonable” or “unreasonable” search in finding that the such a determination is

ultimately a value judgement which the Court may make on a principled basis bearing in mind the context of the individual case. Searches by School Staff However, the above cases concerned searches by police where there are clear legal grounds for the initiation of a warrantless search. Conversely, it is clear that school staff, whether they are the principal or a junior teacher, do not have any formal legal powers to search a student without consent. They rely on the consent of the student to conduct a legitimate search. Any search conducted without consent would accordingly infringe the NZBORA in all but the most extreme exceptions. Nor can school staff claim any inherent rights of search via the in loco parentis doctrine, as it is suggested that [9] their authority is clearly vested in statute, not via assignment by the student’s guardian . Searches by Police Unlike school staff, the Police have powers to conduct searches of premises and individuals without warrant or consent under sections 18(2) and 18(3) of the Misuse of Drugs Act 1975 respectively, based on reasonable grounds for suspecting that the individual or the premises is in possession of illegal drugs.

Despite these broad powers, police must take a number of factors into account when conducting searches in schools. Police officers have certain obligations under the CYPF Act when questioning a young person (aged 16 or younger) in relation to any suspected offence. The most critical of these obligations is the requirement that the young person be given the opportunity to have an independent adult of their choice present, before any questioning takes place (section 215). The police also have developed a General Instruction in relation to interviewing child suspects and witnesses, which follows CYPF Act guidelines. School staff members are not subject to the same requirement as police officers when questioning a student in relation to a suspected offence, although one could raise an argument that a principal could be an enforcement officer for the purposes of the CYPF Act and therefore subject to this requirement. The lack of any requirement for the student to have a parent or supportive adult present during questioning over a drugs incident is problematic, and places the student in a very vulnerable position. However, it follows that any degrading treatment or detention of a student by an interviewing staff member may result in an NZBORA breach, via sections 22 and 23. Drug Testing In addition to searches, drug testing is becoming common in New Zealand schools. Drug testing of

students at school usually occurs where a student who has been suspended for suspected involvement with drugs, is required, as a condition of reinstatement, to agree to drug testing. The issue of “consent” in these situations, is therefore something of a misnomer, as non-compliance usually leads to exclusion. There are clear legal problems facing schools that seek to impose policies of compulsory drug testing as a condition of reinstatement, whether consent is obtained or not. A drug test is a search for the purposes of the NZBORA, and any search obtained through unreasonable means, be it coercion or random testing, may be unlawful. In addition, drug testing procedures such as urinalysis can be degrading and humiliating for the student concerned, especially in circumstances where they are required to perform the test in direct supervision of a staff member Unfortunately there is no New Zealand case law involving drug testing in schools, so there is uncertainty as to how our judiciary might approach such an issue. However, I think that the Court would approach the issue with great caution, in light of the protections of the NZBORA, the requirements of the Privacy Act, the intentions of Parliament in analogous legislation such as the Criminal Investigations (Blood Samples) Act, and the issues of informed consent under the guardianship jurisdiction. In addition, the rights and protections accorded to students under the United Nations Convention on the Rights of the Child, are also of direct legal application to drug searches and testing at school (specifically Articles 16 and 37(b)), and the Courts have indicated a willingness to apply the Convention in their reasoning, where applicable. There has been some case law in the employment jurisdiction concerning compulsory drug testing in the workplace, where drug-testing requirements have been considered harsh and oppressive in some cases (Harrison v Tuckers Wool Processors [1998] 3 ERNZ 418) and reasonable and justifiable in others (Smith v A1 Radiator Specialists Ltd [2001] ELB 52). The nature of the work and the employment agreement are determinative factors. As such, these cases are clearly distinguishable from drug testing in the school environment, which involves a state agency imposing an intrusive procedure upon a minor. Recent US Case Law The US Supreme Court has recently considered the issue of drug testing in US schools (Board of Education of Independent School District No. 92 of Pottawatomie County v Earls, 2002) in relation to the suspicion-less testing of students who participate in extra-curricular school activities. The school in question in this case applied the policy to all extra-curricular activities including such subversive organisations as the school band, the choir, the Academic Team, the Future Farmers of America and the Future Homemakers of America. The Court ruled that this suspicion-less testing did not breach the students right to privacy under the Fourth Amendment of the US Constitution. In reaching its decision Court found that after balancing

the constitutional rights of the student against the “legitimate governmental interests’ of the school, that the students had a “limited expectation of privacy”, due to the “supervision and regulation of all competitive extra-curricular activities”. The Supreme Court decision in Earls expanded their earlier [10] decision in the case of Vernonia , which approved the practice of compulsory, suspicionless drug testing of student athletes. Differing Perspectives on Drug Testing There continues to be considerable debate as to the merits of drug testing as an appropriate response to student drug use at school. Drug Education counsellors have often voiced their concerns that drug [11] testing is counter-productive and does little to address the root cause of student drug use . Schools, on the other hand, tend to see drug testing as a concrete means of ensuring that a student is deterred from further use of drugs. I would argue that the use of drug testing by New Zealand schools as a means of curbing drug use in schools is not particularly constructive, and are more about asserting messages of deterrence and control than about student welfare. Indeed, suspension statistics for drug use have increased since the first reported instances of drug testing in school in 1997. A recent US study (published April 2003) which examined the relationship between student illicit drug use and school drug testing policies, concluded that: “While lack of evidence for the effectiveness of drug testing is not definitive, results suggest that drug testing in schools may not provide a panacea for reducing student drug use that some (including some on the Supreme Court) had hoped. Research has shown that the strongest predictor of student drug use is students’ attitudes toward drug use and perception of peer use.” [12] The study was extensive, with over 70,000 students participating . In addition, a recent UK Home Office Research Report found that zero tolerance drug policies in schools were counter-productive in that such policies encouraged children to conceal their drug use. The research also found that students [13] excluded for drug use developed far more serious drug problems than non-excluded students. This is extremely concerning when one applies this finding into the context of the New Zealand [14] situation, where 30% of all suspended students are excluded (a more specific break-down for drug related exclusions is not available). I believe the current climate in which some schools feel they must resort to drug testing students with [15] behavioural problems to check for P, cocaine or heroin use , or organise police breath testing of [16] students at school balls , indicates a certain level of adult fear concerning adolescent behaviour, manifested in policies and procedures that are fundamentally oppressive in nature. Whilst substances may have changed over time, I would posit that adolescent motivation for using drugs has not changed significantly for generations.

Drug use by school students is ultimately a child welfare issue. The welfare and interests of the child, along with their inherent rights under the Convention, should be the primary consideration of agencies dealing with this issue. At the moment it appears to the writer, in terms of anecdotal experience, that the adversarial nature of the school disciplinary system and the punitive, deterrent means utilized in policing drugs in schools (such as drug testing for example) are fundamentally at odds, philosophically and professionally, with the role of health professionals such as drug counsellors. A joined-up services approach, perhaps using a Strengthening Families or restorative justice model, offers a more holistic, constructive approach and, importantly, ensures that the welfare of the student in question is central to any decision that are made. Such an approach also encourages a degree of meaningful participation by the young person concerned. Moreover oppressive procedures, such as drug testing, are unlikely to instill much respect for those who enforce it, among young people at an impressionable age.

John Hancock YouthLaw Tino Rangatiratanga Taitamariki 27 June 2003

[1] [2] [3]

Ministry of Education Stand-down, Suspension, Exclusion and Expulsion Report, March 2003, www.minedu.co.nz see International Save the Children Alliance, 2002, Child Rights Programming Handbook

Ministry of Education (1996) Guidelines: Guideline 3.4. see also Eddington (2003) Drug Testing and drug searches in New Zealand Schools, YouthLaw Tino Rangatiratanga Taitamariki, Auckland p 14 [4] Education Review Office, Drug Education in Schools Report, June 2002, p 6 [5] Ministry of Education, Drug Education: A Guide for Principals and Boards of Trustees, 2002, p 12

[6] [7] [8]

Eddington, Drug Testing and Searches in New Zealand Schools p 18 section 245

For a much more in-depth and worthy analysis of these issues relating to drug testing and searched in schools see Eddington (2003) Drug Testing and Searches in New Zealand Schools, YouthLaw, Auckland [9] see Crook (1989) In Loco Parentis: Time for reappraisal? Family Law, November p 447-449 and Hancock (2002) Childrenz Issues, Vol 6, No 1 p44-47 [10] Vernonia School District v Acton [1995] 132 L.Ed 2d [11] A Stapp, Some Thoughts on the Ethics of Drug Testing Secondary School Students, ADF Conference 2001 [12] Yamaguchi, Johnston, O’Malley, Relationship Between Student Illicit Drug Use and School Drug-Testing Policies, Journal of School Health, April 2003, Vol. 73, No. 4 [13] Home Office Research Study 260, Reported in The Guardian, February 3, 2003 [14] Ministry of Education Suspension Report, March 2003 [15] http://www.scoop.co.nz/mason/stories/PA0306/S00111.htm [16] Sunday Star-Times, 11 May 2003


								
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