means, because, "a person's private communications are akin to personal papers." Fourth Amendment reasonableness is the point at which the United States government's interest advanced by a particular search or seizure outweighs the loss of individual privacy or freedom of movement that attends the government's action. The United Supreme Court said in Board of Education v. Earls (2002) when 'special needs', beyond the normal need for law enforcement, make the warrant and probable-cause requirement impracticable the reasonableness of a search is determined by balancing the nature of the intrusion on the individual's privacy against the promotion of legitimate governmental interests. Additionally in Illinois v. Lidster (2004) the Court explained in judging reasonableness it looks to "the gravity of the public concerns served by the seizure, the degree to which the seizure advances the public interest, and the severity of the interference with individual liberty". To protect the telecommunication carriers cooperating with the U.S. government from legal action, the Congress passed a bill updating the Foreign Intelligence Surveillance Act of 1978 to permit this type of surveillance. Schools and prisons In New Jersey v. T. L. O. (1985), the Supreme Court ruled that searches in public schools do not require warrants, as long as the searching officers have reasonable grounds for believing the search will result in finding evidence of illegal activity. Similarly, in Samson v. California (2006), the Court ruled that government offices may be searched for evidence of work-related misconduct by government employees on similar grounds. Searches of prison cells are subject to no restraints relating to reasonableness or probable cause. However, in Safford Unified School District v. Redding (2009), the Court ruled that school officials violated the Fourth Amendment when they strip searched a student based only on another student's claiming to have received drugs from her. Exclusionary rule One way courts enforce the Fourth Amendment is through the use of the exclusionary rule. The rule provides that evidence obtained through a violation of the Fourth Amendment is generally not admissible by the prosecution during the defendant's criminal trial. The Court stated in Elkins v. United States (1960) that the rule's function "is to deter—to compel respect for the constitutional guaranty in the only effectively available way—by removing the incentive to disregard it." The Court adopted the exclusionary rule in Weeks v. United States (1914), prior to which all evidence, no matter how seized, could be admitted in