First Circuit
Greenleaf v. Cote, No. CIV. 98-250-B, 2000 WL 863217, at *3 (D. Me. March 3, 2000) (stating that “Jennifer had a clearly established right to be free from an unreasonable search of her belongings by Defendant”).
Third Circuit
Sostarecz v. Misko, No. CIV.A.97-CV-2112, 1999 WL 239401, at *4-5 (E.D. Pa. March 26, 1999) (stating that “school officials are not permitted to unreasonably search a student’s person or her belongings”).
Eighth Circuit
R.S. ex rel. S.S. v. Minnewaska Area Sch. Dist. No. 2149, 894 F. Supp. 2d 1128, 1143 (D. Minn. 2012) (“A student’s right to be free from an unreasonable search—that is, a search without a justifying and legitimate government interest—of private correspondence in school is clearly established.”).
Konop v. Northwestern Sch. Dist., 26 F. Supp.2d 1189, 1196, (D. S.D. 1998) (stating that it was clearly established that school officials could not unreasonably search a student or the student’s belongings).