Hageman Ex Rel. C v. Goshen County School District No. 1, 256 P.3d 487

Goshen County School District No. 1 adopted a policy requiring random drug/alcohol testing for 7th–12th grade students participating in extracurricular activities.
The testing is primarily urinalysis but may use saliva or breath samples, with random selection by an independent firm.
The Coalition of students and parents filed for declaratory judgment challenging the policy as unconstitutional under Wyoming and U.S. constitutions.
The district court granted summary judgment for the District, holding the policy constitutional under both constitutions.
Wyoming Supreme Court reviews de novo the constitutional questions, applying a reasonableness standard to searches and the policy’s rational relation to the district’s safety goals.
The policy is aimed at reducing drug/alcohol use and deterring peer pressure among student athletes and participants in extracurricular activities.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Article 1, § 4 Wyoming Constitution bars the policy as unreasonable search	Coalition argues Article 1, § 4 provides greater protection than the U.S. Fourth Amendment.	District argues Wyoming and federal standards align under reasonableness.	Policy reasonable under all circumstances.
Whether the policy violates Equal Protection	Coalition claims two classes (testers vs non-testers) treated unequally.	Policy applies to all participants in extracurricular activities; no two class disruption.	Equal protection not violated; policy rationally related to safety.
Whether the policy violates Due Process	Testing and final administrative review foreclose judicial review, infringing due process.	Participation in extracurricular activities is not a fundamental right; review not shown denied.	Premature to find due process violation; no demonstrated protected interest adjudicated.
Whether the district should be enjoined from implementing the policy	Unconstitutional policy warrants injunction.	Policy constitutional; no irreparable harm shown.	No injunction granted; summary judgment affirmed.
Whether the district court erred in granting summary judgment	Disputed constitutional questions remain; summary judgment improper.	There are no genuine facts; law supports reasonableness.	Summary judgment affirmed for the District.

Vernonia School Dist. No. 47J v. Acton, 515 U.S. 646 (U.S. Supreme Court, 1995) (reasonableness balanced factors: privacy, intrusion, and efficacy of the policy)
Board of Education of Independent School Dist. No. 92 v. Earls, 536 U.S. 822 (U.S. Supreme Court, 2002) (random, suspicionless testing of all extracurricular participants upheld)
ALJ v. State, 836 P.2d 307 (Wy. 1992) (juvenile probation context; flexibility to permit testing without reasonable suspicion)
Vasquez v. State, 990 P.2d 476 (Wy. 1999) (Wyoming recognizes state constitution as separate source of rights; reasonableness standard)
O'Boyle v. State, 117 P.3d 401 (Wy. 2005) (extends reasonableness analysis to school searches beyond initial context)