Zachary Medlock v. Trustees of Indiana University, 2013 U.S. App. LEXIS 25823

Background

Medlock, an Indiana University dorm resident, consented as a condition of housing to routine health and safety inspections by student resident leaders; inspections were announced in advance.
During a scheduled inspection student inspectors found suspected marijuana in Medlock’s room and saw a large marijuana plant in an ajar closet door; they summoned a university police officer (King).
King observed the plant and took the suspected marijuana; he left to obtain a warrant and posted an officer while awaiting it. A warrant was issued and a further search produced additional marijuana and paraphernalia (89 grams plus a six‑foot plant and grow equipment).
Medlock was suspended/removed from housing for one year (effectively expulsion); criminal charges were later dropped. He sued under 42 U.S.C. § 1983 seeking expungement of the disciplinary record and damages from the student inspectors and Officer King.
The district court granted summary judgment for defendants; the Seventh Circuit affirmed, rejecting Medlock’s due process and Fourth Amendment claims and denying damages and expungement relief.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Medlock was entitled to a pre‑deprivation hearing (due process) before suspension/expulsion	Medlock: denial of a pre‑expulsion hearing violated the Fourteenth Amendment and warrants expungement	University: flagrancy of violations and need for immediate remedial action justified prompt suspension; procedural safeguards were adequate	Court: No merit to due process claim; immediate action was reasonable and expungement not an appropriate remedy
Whether student inspectors’ search violated the Fourth Amendment	Medlock: inspectors’ search was a state‑action search requiring Fourth Amendment protection	Defendants: inspectors acted pursuant to a housing contract consenting to inspections; searches were regulatory and reasonable	Court: Search lawful — Medlock had contractually consented and housing inspections are reasonable regulatory searches
Whether Officer King’s warrantless entry/search violated the Fourth Amendment	Medlock: King’s warrantless involvement converted the inspection into an unlawful police search	King/defendants: he acted reasonably to confirm and secure contraband already discovered by lawful student inspection	Court: No violation — plain view/de minimis principles and reasonableness justified King’s actions; intrusion added nothing material
Whether defendants are liable under § 1983 for damages based on any Fourth Amendment violation	Medlock: damages available for constitutional violation	Defendants: no state‑action or no constitutional violation; even if error, evidence admissible in disciplinary proceeding	Court: Defendants are state actors but there was no constitutional violation; thus no damages

Key Cases Cited

Goss v. Lopez, 419 U.S. 565 (1975) (school disciplinary due process principles supporting immediate action in face of serious misconduct)
Camara v. Municipal Court, 387 U.S. 523 (1967) (reasonableness of administrative inspections and warrant standards)
New Jersey v. T.L.O., 469 U.S. 325 (1985) (lower warrant/probable‑cause standard for school searches)
Griffin v. Wisconsin, 483 U.S. 868 (1987) (special‑needs and diminished privacy in institutional/regulatory contexts)
Vernonia School Dist. 47J v. Acton, 515 U.S. 646 (1995) (reasonableness of searches in the school context under special needs)
Board of Education v. Earls, 536 U.S. 822 (2002) (school‑related regulatory searches and student privacy)
Hudson v. Michigan, 547 U.S. 586 (2006) (availability of damages for Fourth Amendment violations)
Pennsylvania Bd. of Probation & Parole v. Scott, 524 U.S. 357 (1998) (limitations of exclusionary rule to criminal proceedings)
United States v. Calandra, 414 U.S. 338 (1974) (scope of exclusionary rule and remedies)
Platteville Area Apartment Ass'n v. City of Platteville, 179 F.3d 574 (7th Cir.) (reasonableness of compulsory housing inspections to enforce regulatory codes)
Osteen v. Henley, 13 F.3d 221 (7th Cir.) (reluctance to judicialize university disciplinary processes)