The Supreme Court has not ruled on the constitutional limits of using drug-sniffing dogs in schools at the time of this publication, and the lower courts have had differing opinions on whether such tactics are in violation of the reasonable suspicion test. Some courts have held that a sniffer dog does not constitute a search at all, with the landmark case being Doe v. Renfrow (1980). Students who were singled out by dogs in this case were subjected to a strip search, which the Supreme court held was unreasonable. In Horton v. Goose Creek Independent School District (1982) courts held that sniffing a person was a search and that such a search was a violation of Fourth Amendment rights unless there was reasonable suspicion as dictated by T.L.O.

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