People In Interest of J.G.

CourtColorado Court of Appeals
DecidedJune 16, 2022
Docket20CA0218
StatusPublished

This text of People In Interest of J.G. (People In Interest of J.G.) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People In Interest of J.G., (Colo. Ct. App. 2022).

Opinion

The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the language in the summary and in the opinion should be resolved in favor of the language in the opinion.

SUMMARY June 16, 2022

2022COA64

No. 20CA0218, People in Interest of J.G. — Juvenile Court — Delinquency; Constitutional Law — Fourth Amendment — Searches and Seizures — Searches in School Settings

A juvenile appeals the judgment adjudicating him delinquent

for possessing a handgun as a second-time juvenile offender and

possessing a weapon on school grounds. The juvenile contends

that the juvenile court erred by denying his motion to suppress the

gun because school officials discovered it in the course of an

unreasonable search of his backpack at school.

In this case, a division of the court of appeals applies the two-

part test established in New Jersey v. T.L.O., 469 U.S. 325, 341

(1985), to novel facts. The T.L.O. Court laid out a two-part inquiry

for determining reasonableness. Under T.L.O., a court must first

determine whether the search was justified at its inception, and then determine whether the search was reasonably related in scope

to the circumstances that initially justified the interference. Id.

This case concerns the application of the first part of the inquiry.

Under ordinary circumstances, a search of a student at school

is “justified at its inception” when a school official has reasonable

suspicion that a search will turn up evidence that the student has

violated or is violating either the law or the rules of the school. The

division concludes that reasonable suspicion is a sufficient, but not

necessary, means of justifying a search at its inception under T.L.O.

The division holds that a search may be justified at its

inception without reasonable suspicion where the record shows that

the student had a substantially diminished expectation of privacy in

his or her person or property. Because the high school here

implemented a safety plan for the juvenile that included a search

requirement, the division concludes that J.G. didn’t have a

legitimate expectation of privacy in his backpack and that the

search was justified at its inception even without reasonable

suspicion of other wrongdoing. Accordingly, the division affirms. COLORADO COURT OF APPEALS 2022COA64

Court of Appeals No. 20CA0218 City and County of Denver Juvenile Court No. 19JD641 Honorable Laurie A. Clark, Judge

The People of the State of Colorado,

Petitioner-Appellee,

In the Interest of J.G.,

Juvenile-Appellant.

JUDGMENT AFFIRMED

Division VI Opinion by JUDGE WELLING Fox and Johnson, JJ., concur

Announced June 16, 2022

Philip J. Weiser, Attorney General, Melissa D. Allen, Senior Assistant Attorney General, Denver, Colorado, for Petitioner-Appellee

Megan A. Ring, Colorado State Public Defender, Mark Evans, Deputy State Public Defender, Denver, Colorado, for Juvenile-Appellant ¶1 J.G., a juvenile, appeals the judgment adjudicating him

delinquent based on findings that he possessed a handgun as a

second-time juvenile offender, see § 18-12-108.5(1), C.R.S. 2021,

and possessed a weapon on school grounds, see § 18-12-105.5,

C.R.S. 2021. He contends that the juvenile court erred by denying

his motion to suppress the gun because school officials discovered

it in the course of an unreasonable search of his backpack at

school.

¶2 This case involves a novel application of an established legal

test. In New Jersey v. T.L.O., 469 U.S. 325, 341 (1985), the

Supreme Court held that the legality of a search of a student in the

school context depends “simply on the reasonableness, under all

the circumstances, of the search.” The T.L.O. Court laid out a two-

part inquiry for determining reasonableness. Id. First, a court

must determine whether the search was justified at its inception.

Id. Second, a court must determine whether the search was

reasonably related in scope to the circumstances that initially

justified the interference. Id. This case concerns the application of

the first part of the inquiry.

1 ¶3 Under ordinary circumstances, a search of a student at school

is “justified at its inception” when a school official has reasonable

suspicion that a search will turn up evidence that the student has

violated or is violating either the law or the rules of the school. Id.

at 341-42. We conclude that reasonable suspicion is a sufficient,

but not necessary, means of justifying a search at its inception.

¶4 A search may be justified at its inception without reasonable

suspicion where the record shows that the student had a

substantially diminished expectation of privacy in his or her person

or property. Because the high school here implemented a Safety

Plan for J.G. that included a search requirement, J.G. didn’t have a

legitimate expectation of privacy in his backpack sufficient to trigger

a warrant requirement. And based on this, we conclude that the

search was justified at its inception even without reasonable

suspicion of other wrongdoing. Accordingly, we affirm.

I. Background

A. Overview

¶5 J.G. attended a public high school in Denver. In December

2018, the juvenile court adjudicated J.G. delinquent for two

offenses: felony menacing and possession of a handgun by a

2 juvenile. Based on this adjudication, on January 15, 2019, the

school’s Threat Appraisal Team completed a Preliminary

Information Gathering Form (PIGF) and a Full Threat Appraisal

(FTA).

¶6 The Threat Appraisal Team used the FTA to develop an Action

and Intervention Plan, which we will refer to as J.G.’s “Safety Plan,”

as that is the nomenclature used before the juvenile court. Officer

Johnny Avila, the School Resource Officer, participated in creating

the Safety Plan. J.G.’s mother, J.G.’s guardian ad litem, the Dean

of Students, and several other school officials also participated.

¶7 In February 2019, J.G. was involved in a motor vehicle theft.

J.G.’s companion in that incident unlawfully possessed a firearm

during the theft. Following that incident, J.G. remained in

detention until April 2019. On April 22, 2019, to support J.G.’s

transition back to school, the Threat Appraisal Team conducted

another assessment and amended the Safety Plan.

¶8 School officials conducted the search at issue in this case

pursuant to the Safety Plan. The parties contest whether the Safety

Plan justified the search.

3 B. PIGF, Original Safety Plan, and Amended Safety Plan

¶9 The PIGF is the first part of Denver Public Schools’ “Threat

Response System.” The PIGF consists of six steps that help the

Threat Appraisal Team complete the FTA, which, once completed,

became J.G.’s Safety Plan. Step one, titled “Make Sure All Students

Are Safe,” includes several boxes, only one of which the Threat

Appraisal Team checked:

¶ 10 In step six, titled “Determine next steps,” the Threat Appraisal

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People In Interest of J.G., Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-in-interest-of-jg-coloctapp-2022.