afforded the same level of protection for search and seizures as adults and juveniles in non-school settings. Justice William J. Brennan, joined by Justice Thurgood Marshall, agreed with the majority's conclusions about the applicability of the Fourth Amendment to school teachers but dissented from the new standard set down by the Court, which he felt was a departure from the traditional "probable cause" approach. Brennan went on to argue that for the government to justify a warrantless search, some "special governmental interest" outside of standard law enforcement interests was required. This idea was later adopted by the Court as the special needs doctrine. See also List of United States Supreme Court cases, volume 469 Vernonia School District 47J v. Acton, 515 U.S. 649 (1995) Board of Education v. Earls, 536 U.S. 822 (2002) Safford Unified School District v. Redding, 557 U.S. 364 (2009) Special needs exception Terry v. Ohio, 392 U.S. 1 (1968) Cohen v. California, 403 U.S. 15 (1971) Footnotes References References Sources New Jersey v. T. L. O., 469 U.S. 325 (1985) External links Summary on LandmarkCases.org United States Supreme Court cases United States Supreme Court cases of the Burger Court United States Fourth Amendment case law Student rights case law in the United States United States controlled substances case law 1985 in United States case law 1985 in education Piscataway, New Jersey Cannabis in New Jersey Education in Middlesex County, New Jersey Smoking in the United States