However, the Court also found that because there was sufficient doubt as to whether the law was clearly established at the time of the search, the school officials were shielded from liability by qualified immunity.

(1985) that the public interest in maintaining the school environment "'is best served by a Fourth Amendment standard of reasonableness that stops short of probable cause'".

Wilson showed Redding a day planner which had "several knives, lighters, a permanent marker, and a cigarette" inside, and he asked if it was hers.

Redding agreed to let Wilson and an administrative assistant named Helen Romero search her backpack, which did not reveal any pills.

[11] Wilson then took Marissa Glines out of class and, in the presence of Helen Romero, asked her to "turn out her pockets and open her wallet", which "produced a blue pill, several white ones, and a razor blade".

[13] On July 11, 2008, after rehearing the case en banc, the Ninth Circuit reversed the panel, holding in a closely divided decision that the search violated the Fourth Amendment and that assistant principal Wilson was not entitled to qualified immunity.

[14] The en banc Ninth Circuit affirmed that defendants Romero and Schwallier were entitled to qualified immunity because "they had not acted as independent decisionmakers".

[21] Souter reiterated that in T. L. O., the Court had held that the scope of a school search "will be permissible ... when it is 'not excessively intrusive in light of the age and sex of the student and the nature of the infraction".

[22] From this, he concluded that in Redding's case, "the content of the suspicion failed to match the degree of intrusion" because assistant principal Wilson "must have been aware of the nature and limited threat of the specific drugs he was searching for".

[28] Souter commented that "the cases viewing school strip searches differently from the way we see them are numerous enough, with well-reasoned majority and dissenting opinions, to counsel doubt that we were sufficiently clear in the prior statement of law".

[30] Souter clarified that the Court's "conclusions here do not resolve, however, the question of the liability of petitioner Safford Unified School District #1 under Monell v. New York City Dept.

[32] He disagreed that the "seemingly divergent views" among lower courts of appeals about T. L. O.’s application to strip searches justifies extending qualified immunity, stating that "the clarity of a well-established right should not depend on whether jurists have misread our precedents".

"[34] In Ginsburg's view, "'the nature of the [supposed] infraction,' the slim basis for suspecting Savana Redding, and her 'age and sex', establish beyond doubt that Assistant Principal Wilson's order cannot be reconciled with this Court's opinion in T. L. O. Wilson's treatment of Redding was abusive, and it was not reasonable for him to believe that the law permitted it.

[37] Katz and Mazzone described the Court's decision in Redding as "a step in the right direction, clarifying T. L. O. and instructing that school strip searches are to be treated as extraordinary intrusions supported by individualized reasonable suspicion and subject to the proportionality standard".

[43] The Harvard Journal of Law & Gender published a commentary by Laura Jarrett, who stated that "although the majority correctly found the strip search of Savana Redding excessively intrusive under the circumstances, one major aspect of the standard set forth in T. L. O. was neither fully explained nor applied by the Court in Redding—namely, the role sex plays in evaluating the legality of a strip search".

[45] Jarrett commented that the Court's "failure to address in Redding the sex prong required under T. L. O. might leave the case open to potentially undesired interpretations in the future" and that this may "place school officials in a position to again receive immunity for such abuses of students' rights".

[46] In an article published in the Brigham Young University Journal of Public Law, Eric W. Clarke wrote that "a likely result of Safford is that school officials now have more protections than qualified immunity normally grants".

"[50] Katz and Mazzone, on the other hand, directly criticized the Court's decision to grant qualified immunity to the assistant principal as "misguided", stating that "Wilson's actions defied the common sense one would expect in an experienced administrator".

[43] After the decision was announced, Adam Liptak wrote an article published in The New York Times, in which he stated that the case "had attracted national attention and gave rise to an intense debate over how much leeway school officials should have in enforcing zero-tolerance policies for drugs and violence".

[51] According to Liptak, "Some parents were outraged by the intrusiveness of the search, while others worried about tying the hands of school officials charged with keeping their children safe.

[52] Matthew W. Wright, the lawyer that argued for the school district in the Supreme Court, "said that the decision 'offers little clarification' concerning when such searches are allowed and that it could have dangerous consequences".

"[52] On the other hand, Francisco Negron, general counsel for the National School Boards Association, criticized the decision as lacking clarity, stating that "The home medicine cabinet now poses a serious threat to students, who may take those medications for abusive purposes.

[55] In September 2020, following Ginsburg's death, Valerie Strauss wrote an article published in The Washington Post, which described the Redding case as serving "to underscore the humanity with which [Justice Ginsburg] approached her decisions and why many court watchers say it is so important for the Supreme Court to include a diverse group of justices with different experiences and points of view".