In the case of Vernonia School District 47J v. Wayne Acton, et ux., etc., in 1994, the U.S Supreme Court ruled that random drug testing of student athletes by public schools does not violate the Fourth Amendment's prohibition against unreasonable searches and seizures. The court held that even though such tests are searches under the Fourth Amendment, they could be justified as a reasonable method to prevent and deter drug use among students. The decision was based on several factors including: increased drug use in school districts; connection between drugs and sports-related injuries; voluntary nature of participation in athletics; reduced expectations of privacy for student-athletes due to communal undress inherent in athletic participation; minimal intrusion caused by urine samples compared with typical requirements for physical exams or vaccinations necessary for school attendance.

In the dissenting opinion for Vernonia School District 47J v. Wayne Acton, Justice O'Connor argued that the majority's decision to uphold random drug testing of student athletes was a violation of their Fourth Amendment rights against unreasonable searches and seizures. She contended that there was insufficient evidence to suggest a pervasive drug problem among student athletes specifically, which could justify such an invasive policy. Furthermore, she disagreed with the majority's assertion that students have lesser expectations of privacy than adults in other settings; instead, she believed schools should be places where young people learn about their constitutional rights and protections. Lastly, Justice O'Connor expressed concern over potential misuse or expansion of this ruling by school administrators who might extend testing beyond its original intent.