Safford Unified School District v. Redding
Summarize your case. What happened? Why was the nurse involved?
The law case is used to show why the school nurse was named. How does the history of school nursing have any effect on what happened in the case?
What federal law would the case fall under? FERPA? FAPE? IDEA? TITLE IX? CIVIL RIGHTS?
What Pennsylvania state law could apply to this case? If your case takes place in NY or Ohio, you are still going to apply a PA state law. Many of the PA state laws can be found via
search on your case (food allergies, concussion, PA Public School Code, Environmental Issues, etc.) on the PA Department of Health, School Health website
here
What School Nursing: Scope and Standards of professional practice were not met. If the nurse Was the nurse excused from the case? What did the nurse do that showed she adhered to these practices?
What provisions of the Code of Ethics were disregarded? If the nurse was excused from the case, what did the nurse do that showed she abided by the Code
NASN Code of Ethics
Legal Case Review: Safford Unified School District v. Redding
Case Summary
Safford Unified School District v. The Redding, 557 U.S. 364 (2009), case is a historic case of the United States Supreme Court on the Fourth Amendment rights of learners in the public schools. The case focused on Savana Redding, a 13-year-old who was in grade 8 at the Safford Middle School in Safford, Arizona. Assistant Principal Kerry Wilson was tipped off by another student in October 2003, and Savana was allegedly selling prescription-strength ibuprofen (400 mg) and over-the-counter naproxen (200 mg) to other students against the school’s zero-tolerance drug policy. Following this piece of information, Wilson searched the backpack and outer clothes of Savana, finding nothing. Then he instructed the school nurse, Helen Romero, and an administrative assistant, Peggy Schwallier, to strip-search the student in the office of the nurse.
In the process of searching, Savana was asked to take off her outer garments to expose her breasts and pelvis region by taking off her bra and underwear. No drugs were found. Savana was later sued by her mother, April Redding, who claimed that the strip search infringed the Fourth Amendment right of Savana, which prohibited unreasonable search and seizure. The school nurse was a party to the suit since she was present physically when the search took place and was also involved in its performance. The Supreme Court came to the conclusion that the strip search was not constitutional as it was too intrusive due to the small suspected violation Safford Unified School District v. Redding. The qualified immunity offered to the nurse and other school officials meant that they were not personally liable, as the breach of the constitutional provision was not evident when the incident happened. However, the case posed some deep questions regarding the role of school nurses to uphold the dignity and privacy of students and their well-being (Smith, 2022).
Application to Readings
History of School Nursing
The history of school nursing in the United States offers the necessary background of the situation and role of the nurse in the case of Safford v. Redding. School nursing originated in New York City in 1902, as Lina Rogers was the first trained school nurse whose main task was to ensure that the number of absentees because of communicable diseases was reduced (Resha & Taliaferro, 2024). Gradually the role of school nurses grew considerably beyond controlling the spread of infectious diseases into the provision and assessment of student health, administration of medication, chronic illnesses, and promotion of student health rights.
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With the development of the profession, school nurses were accepted to be the primary champions of student safety and well-being in the school setting. In 1968, the National Association of School Nurses (NASN) was organized and established formal standards of practice to regulate ethical and safe nursing practice in the school (NASN, 2022). At the beginning of the 2000s, school nurses started to become a new focal point of healthcare, legislation, and education policy. It was this positioning that put nurses like Helen Romero in a position when they were requested to execute orders of school administrators without adequate legal advice or consultations with other professionals. In the past, school nurses often worked under the umbrella of principals and administrators and not under clinical judgment, and this was a direct contributory factor to the nurse in this case involving the strip search. The history of school nursing developing into autonomous, evidence-based, and rights-conscious practice underscores the professional expectation of the nurse to have noticed the inappropriateness of the directive and defend the student (Resha and Taliaferro, 2024).
Federal Law
The federal law that is most relevant to Safford v. The fourth amendment to the United States Constitution is known as Redding, and it has banned unreasonable searches and seizures by the government actors, including the officials of the public school. The public school officials are under the standard of reasonableness of searches of students, per the precedent of New Jersey v. T.L.O., 469 U.S.325, 1985; they need no search warrant but only a reasonable suspicion that a search will yield evidence of a violation of a rule or a law. In Safford v. The Supreme Court, after which Redding argued, concluded that although the school officials had a reasonable suspicion to check the contents of the backpack and outer garments belonging to Savana, the strip search was not constitutionally reasonable because the officials did not have any factual evidence that the drugs were hidden in her undergarments, and the allegation of the infraction was not so egregious as to warrant such an invasive investigation (Safford Unified School District v. Redding, 2009).
The subject of Title IX of the Education Amendments of 1972, which outlaws sex-based discrimination in education programs funded by the federal government, is also applicable since the sexualized and gendered character of the search had a disproportionate effect on the dignity of a female student. Nonetheless, the main federal constitutional framework employed in the case is the Fourth Amendment. The case has become a pivotal federal precedent that determines that students have a reasonable expectation of privacy in their bodies in publicly funded schools and that school health officials can be involved in civil rights violations by performing constitutionally suspect searches (Resha and Taliaferro, 2024). School nurses should then be aware of the constitutional rights of students and realize that being submissive to an administrator does not protect them against professional or ethical liability.
State Law
Although Safford v. Redding, Arizona, is where the case is filed, the Pennsylvania Public School Code of 1949 (24 P.S. 1-101 et seq.) is the Pennsylvania state law that appears to be the most relevant to the facts of the case, especially concerning health services offered to students, student rights, and the administration of medications at schools. According to section 1414 of the Pennsylvania School Code, school health personnel as well as the nurses have a role to play in ensuring the safety and well-being of the students (Pennsylvania Public School Code, 1949). Most importantly, the regulations that govern the school health of the Pennsylvania Department of Health stipulate that school nurses facilitate within a professional scope of practice and that they are not simply the administrative tool.
According to Pennsylvania laws, drugs should be administered in schools in accordance with the suggested standards, such as the approval of a physician, parental consent, and appropriate documentation (Cogen et al., 2024). In Pennsylvania, the school nurse would have been supposed to interpret any exposure to medication as a clinical issue, in which the rights and health needs of the school child would have been taken into consideration in accordance with the law. The Pennsylvania School Code equally upholds that the students have the right to privacy and dignity when undergoing health-related assessments. Safford Unified School District v. Redding A strip search directed by a school administrator, with no clinical reason, and without warning of the parents, would run counter to the safeguards inherent in state health regulations as well as to those of the general structure of the PA Public School Code. This would not allow the school nurse to take on a professional judgment and decline to engage in a search that did not have a reasonable clinical or legal foundation (Resha and Taliaferro, 2024).
School Nursing Standards of Practice and Professional Performance.
ANA and NASW School Nursing: Scope and Standards of Practice (3rd ed., 2017) identifies 18 standards underpinning competent and ethical school nursing practice. There are two standards that are specifically applicable in Safford v. Redding: Standard 1 (Assessment) and Standard 7 (Ethics).
Standard 1, Assessment, demands that the school nurse gather relevant data and information that is relative to the health and well-being of the student by applying relevant evidence-based assessment techniques and tools (Gawlik et al., 2024). Applying this standard competently in the context of this case would have meant that Nurse Romero would have done a clinical evaluation of the situation before being involved in the search. This evaluation would have involved evaluating the existence of a legitimate clinical basis for the search, whether any sign of medication misuse or impairment was present in the student, and whether parental notification had been undertaken. Rather, the nurse went further to process the search only on the instruction of an administrator without any professional analysis. The lack of standard assessment principles prior to conducting an act put the student in danger of physical and psychological injuries and was a serious deviation from the evidence-based nursing practice (Resha and Taliaferro, 2024).
Ethics Standard 7, Ethics, requires the school nurse to act with ethical practice, incorporate the ethical aspects of the nursing profession in all their practice areas, and promote the health, safety, and rights of the student. The strip search of the 13-year-old girl student was a serious infringement of the girl child’s dignity and right to privacy. The ethical nursing practice would have involved the nurse recognizing the possible harm of the search, expressing her professional opposition, and defending the rights of the student instead of acting as an enforcement mechanism. Direct opposition to the ethical requirements entrenched in Standard 7 was the fact that the nurse did not object to or advocate for the search. A professional role that school nurses should assume is being the health advocate of the student, but not a continuation of school disciplinary mechanisms, especially in cases when the suggested measure presupposes the invasive examination of a minor.
Code of Ethics of the American Nurses Association.
The ANA Code of Ethics provides the ethical requirements of all registered nurses irrespective of the practice environment. The first provision of the code is that the nurse carries out his or her work with care and respect for the existing dignity, value, and distinctive qualities of each individual. The interpretive statements in Provision 1.1 indicate that the nurse should uphold human dignity in all professional interactions, safeguarding the right of self-determination and privacy of the patient.
The Safford case was a direct violation of provision 1. The strip search caused Savana Redding a lot of humiliation and psychological trauma. Savana went on to say that the experience was highly distressing, and the search made her body vulnerable in a way that no medical or safety considerations were relevant in the situation. Nurse Romero did not live up to her responsibility of preserving the natural dignity and value of Savana by being involved in the search. The ANA Code, provision 1.2, underlines the fact that the nurse should be sensitive to the vulnerability of the patient, especially when it comes to cases of coercive relationships. A school-going child ordered by an official to strip to unfamiliar people at school is obviously not in a strong position. The moral duty of the nurse in the given situation was not to participate in the coercive action but to protect the student against the latter (Anastasi et al., 2024). Nurse Romero should have shown the compassionate respect required under Provision 1 and might have avoided the constitutional infraction that eventually made it to the Supreme Court had she not consented to be involved but instead proposed a less invasive and properly authorized alternative Safford Unified School District v. Redding.
Conclusion
City of Safford Unified School District v. Redding is a landmark decision that is still relevant in the crossroads of school law, student rights, and school nursing practice. The case shows that the historical role of school nurses as subordinate to the administrative power, instead of being independent professional advocates, can be the cause of significant ethically and legally violating practices. The failure of the nurse to demonstrate professional judgment and ethical advocacy made it possible to perpetrate the Fourth Amendment violation that is at the core of the case. The pertinent federal constitutional safeguards, Pennsylvania state health statute, ANA/NASN Standards of Practice (Standard 1 and Standard 7), and ANA Code of Ethics Provision 1 all intersect at the point where the school nurse has the responsibility of upholding student dignity, safety, and rights over administrative compliance.
The school nurse is not an inactive party involved in school activities but a licensed professional who has legal and ethical responsibility towards the students under his or her care, which is independent of the school. The case is also a good reminder that professional advocacy, ethical clarity, and legal knowledge are not just competencies but also some of the required foundations of safe and responsible school nursing practice. As the profession keeps changing, the school nurses need to be enabled to challenge the orders that do not align with the interests of the students and act as the ultimate shield against the most vulnerable members of society (Smith, 2022).
References
Anastasi, G., Latina, R., Longobucco, Y., Stievano, A., & Bambi, S. (2024). Exploring Nurses’ and Nursing Students’ Attitudes Toward Coercive and Technological Measures in Mental Health: A Conceptual Framework and Study Protocol.
Nursing Reports
,
14
(4), 4129-4144.
https://www.mdpi.com/2039-4403/14/4/301
Cogen, F., Rodriguez, H., March, C. A., Muñoz, C. E., McManemin, J., Pellizzari, M., … & Sherman, J. (2024). Diabetes care in the school setting: a statement of the American Diabetes Association.
Diabetes Care
,
47
(12), 2050-2061.
https://diabetesjournals.org/care/article-abstract/47/12/2050/157411
Gawlik, K., Melnyk, B. M., & Teall, A. (Eds.). (2024).
Evidence-based physical examination: Best practices for health and well-being assessment
. Springer Publishing Company.
https://books.google.com/books?hl=en&lr=&id=6tXSEAAAQBAJ&oi=fnd&pg=PP1&dq=school+nurse+gather+relevant+data+and+information+that+is+relative+to+the+health+and+well-being+of+the+student+by+applying+relevant+evidence-based+assessment+techniques+and+tools&ots=0n_Lu8E_dX&sig=5LXmPmJwvoIzrhhxmizLoI2LFFM
National Association of School Nurses. (2022).
About NASN
.
https://www.nasn.org/nasn/about-nasn/about
Pennsylvania Public School Code of 1949
, 24 Pa. Stat. § 1-101
et seq
. (1949 & rev. 2022).
https://www.legis.state.pa.us/cfdocs/legis/LI/uconsCheck.cfm?txtType=HTM&yr=1949&sessInd=0&smthLwInd=0&act=14
Resha, C., & Taliaferro, V. (2024).
Legal resource for school health
(2nd ed.). National Association of School Nurses.
Safford Unified School District v. Redding
, 557 U.S. 364 (2009).
https://supreme.justia.com/cases/federal/us/557/364/
Smith, S. (2022). The Problem of Qualified Immunity in K-12 Schools.
Arkansas Law Review
,
74
(4), 7.
https://scholarworks.uark.edu/alr/vol74/iss4/7/
Safford Unified School District v. Redding
Safford Unified School District v. Redding NURS 508 Practical Exercise Paper Rubric
NURS 508 Practical Exercise Paper
Criteria
Level 4
Level 3
Level 2
Level 1
Criterion Score
Criteria 1-
Introduction Summary
15 Points-
The legal case is summarized with relevant issues related to the school nurse’s role
12 Points-
Most of the important aspects of the case is summarized
9 Points-
The important aspects of the case is briefly summarized
0 Points-
The summarization of the case is minimal or absent
/15
Criteria 2-
25 points
Each topic is thoroughly addressed:
-History of school nursing about your case.
-One federal law applying to the case.
-One PA law applies to the case.
ANA & NASN School Nursing: Scope and Standards of Practice- Choose 2 of the 18 and then apply them to your case.
-ANA Code of Ethics- Choose 1 provision and its interpretive statement and apply it to your case.
20 points
Each topic is addressed somewhat thoroughly but has missing information or lacks organization.
15 points
Most topics are addressed, while others lack information and organization
10 points
Few topics were addressed but much information missing and disorganized.
/25
Criteria 3
Required citations and references
5 points
Utilized all required citations and references
3 points
Utilized most required citations and references
2 points
Utilized some of required citations and references
1 point
Utilized few required citations and references
/5
Criterion 4
Language use and references in APA 7
th
edition format
5 points
Minimal grammatical mistakes and use of APA 7
th
edition format throughout the Safford Unified School District v. Redding paper
3 points
Few grammatical errors and use of APA 7
th
edition format throughout the paper
2 points
Many grammatical errors and use of APA 7
th
edition format throughout the paper
1 point
Significant number of grammatical errors and use of APA 7
th
edition format throughout the paper.
/5
Total:
/50
Safford Unified School District v. Redding Practical Exercise: Case Law Review Information
You have each been assigned a legal case, though some of these are on the older side; the information remains pertinent. Complete an internet search for your assigned case. The cases are not provided by your instructor. You may also use legal sources such as Wright’s Law, Justia, FindLaw, and Casetext to locate the basic idea of the case. The EU library will not be a primary source for this information.
You don’t need to focus on how the case was processed through the court system; focus on the case’s basic idea (background, why it was brought, and the nurse’s involvement). You will likely encounter legal terminology that you aren’t expected to understand or interpret.
You can find more information about the Practical Exercise Paper here:
Practical Exercise Paper
The rubric for the paper is found under Practical Exercise Assignment: Content->Rubrics-> Practical Exercise
Summarize your case. What happened? Why was the nurse involved?
The law case is used to show why the school nurse was named. How does the history of school nursing have any effect on what happened in the case?
What federal law would the case fall under? FERPA? FAPE? IDEA? TITLE IX? CIVIL RIGHTS?
What Pennsylvania state law could apply to this case? If your case takes place in NY or
Ohio, you are still going to apply a PA state law. Many of the PA state laws can be found via
search on your case (food allergies, concussion, PA Public School Code, Environmental Issues, etc.) on the PA Department of Health, School Health website
here
What School Nursing: Scope and Standards of professional practice were not met. If the nurse
Was the nurse excused from the case? What did the nurse do that showed she adhered to these practices?
What provisions of the Code of Ethics were disregarded? If the nurse was excused from the
case, what did the nurse do that showed she abided by the Code
NASN Code of Ethics
Assignment Specifics:
The paper should be 4-6 pages typed, written in APA format
The title page and the reference page are in addition to the required 4-6 pages of written work.
Papers must conform to the 7th edition Publication Manual of the American Psychological Association for guidelines regarding APA style for written work. APA resources in Content.
It is expected that the paper will be written at the graduate course level.
Please follow the Practical Exercise Grading Rubric in Content
All papers submitted to Dropbox are automatically processed via Turnitin.com for plagiarism detection. All papers must have a Turnitin score of less than 25%. Before submitting your final paper to the Assignment Dropbox, be sure to submit to the
Draft box
until you complete your edits.
You are able to submit to the Draft box as many times as needed without negatively impacting your Turnitin score.
Papers that do not meet the criteria will be graded per the rubric. Academic dishonesty is not tolerated! Please see the syllabus and content for further information.
PEPARING FOR YOUR Safford Unified School District v. Redding PE LAW CASE ASSIGNMENT
Locating Your Assigned Legal Case
Content
Assignments in Detail
Practical Exercise (PE) /Case Law Review *Assigned cases listed here!
Find your name listed next to the law case
Paper expectations, requirements and due date found in Assignments in Detail and the Syllabus
Students are assigned a legal case in which a school nurse was named in the school district suit. The case is from various states in the U.S. and not specific to Pennsylvania.
If the nurse was dismissed from the case, you will still explain why and how the nurse did follow the law or what she/he could have done better in application to the law, code of ethics, standards, etc. following the rubric.
You are responsible for locating these cases via the internet. The cases are not provided by the instructor.
Students are advised to use legal sources such as Wright’s Law, Justia, FindLaw, Casetext and general internet searches to locate the basic idea of the case.
Students do not need to use the EU library.
The easiest way to find information on your case is a general Google search using the title of your assigned case. Many links will pop up for your review so that you gain a general knowledge of what happened.
The assignment is not about knowing how the case processed through the legal system, the level of courts, appeals, etc. it is only the
basic idea of the case and the nurse’s involvement
. Students are not expected to understand the legal jargon and interpret it.
When writing your paper follow the rubric for the PE assignment. This is found in Content>Rubrics> Practical Exercise
Summarize your law case. What happened? Why was the nurse involved?
The law case is used to show why the school nurse was named. How does the history of school nursing have any effect on what happened in the case? WEEK 1 Session Information
What federal law would the case fall under? FERPA? FAPE? IDEA? TITLE IX? CIVIL RIGHTS? Weeks 2-6 Session Information and Resha & Taliaferro text (2017)
What PENNSYLVAINA state law could be applied to this case. If your case takes place in NY or Ohio, you are still going to apply a PA state law. Many of the PA state laws can be found via search on your case (food allergies, concussion, PA Public School Code, Environmental Issues etc.) on the PA Department of Health, School Health website: https://www.health.pa.gov/topics/school/Pages/School%20Health.aspx and in Week 4 Session assignment
What School Nursing: Scope and Standards of professional practice were not met. If the nurse was excused from the case, what did the nurse do that showed she did abide by these practices. WEEK 5 Session information and from the required ANA, 2017 text.
What provisions of the Code of Ethics were disregarded? If the nurse was excused from the case, what did the nurse do that showed she abided by the Code. WEEK 6 Session Information ANA Code of Ethics
Any questions or concerns, please contact the instructor for assistance.
Graded Assignment: Practical Exercise: A Case Law Review
Course Outcomes Fulfilled: All
Grading Value: 25%
Class Session Due: Week 14
By utilizing the assigned legal case the student will summarize the legal case and provide a description of its relevance to school nurse practice.
Assignment Objectives:
At the conclusion of the assignment, the student will be able to:
Relate the history of school nursing impact on the assigned case.
Apply Federal and Pennsylvania State Law to the case.
Interpret the Standards of Nursing Practice and Performance applicable to the case
Select statements and provisions of the Nursing Code of Ethics and appraise ethical consideration within the case
Demonstrate proper APA 7
th
edition citation and graduate writing ability
Safford Unified School District v. Redding
Assignment Specifics:
The paper should be 4-6 pages typed, written paper in APA format
The title page and the reference page are in addition to the required 4-6 pages of written work.
Papers must conform to the 7
th
edition
Publication Manual of the American Psychological Association for guidelines
regarding APA style for written work. APA resources in Content.
It is expected the paper will be written at the graduate course level.
Please follow the Practical Exercise Grading Rubric in Content.
All papers once submitted to Dropbox are automatically processed via Turnitin.com for plagiarism. All papers must have less than 25% Turnitin score. Papers that do not meet the criteria will be graded per the rubric. Academic dishonesty is not tolerated! Please see the syllabus and content for further information Safford Unified School District v. Redding.
Please refer to Content>Assignments in Detail to see additional information on how to research and prepare your formal Practical Exercise paper!
Please Note:
You are responsible for locating these cases via an internet search. Many of the cases have details in accompanying news articles and/or may be located via actual court documents.
A general online search will elicit all of the information you need to complete this assignment.
Cases that are dually assigned are to be done independently.
Even though the case may be filed in a state other than Pennsylvania, you will be applying Pennsylvania law to the case in your written assignment.
If the Safford Unified School District v. Redding nurse was dismissed from the case, you will still explain why and how the nurse did follow the law to be excused and what she/he could have done better in application to the law, code of ethics, standards, etc. following the rubric.
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