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However, there are two related areas of Fourth Amendment protection where consent is not needed for a warrantless search: (A) Supervisory Searches - The warrantless search of an employee's desk or file cabinet by a supervisor is reasonable if made for noninvestigatory, work-related purposes or to investigate work-related misconduct. O'Connor v. Ortega, 480 U.S. 709 (1987); (B) School Searches - the U. S. Supreme Court approved a warrantless search of a public school student by school authorities, by balancing the school's need to maintain safety, order, and discipline against the student's right of privacy. New Jersey v. T.L.O., 469 U.S. 325 (1985). School administrators and officials may conduct reasonable searches on school property of lockers, desks, vehicles, and personal belongings such as purses, bookbags, wallets, and satchels with or without probable cause. School principals or their designees may conduct reasonable searches of the person and property of visitors on school premises. Notice must be conspicuously posted on school property, at all regular entrances and any other access point to the school grounds. Searches conducted under provisions of these statutes must be reasonable as set forth in New Jersey v. T.L.O. S.C. Code 59-63-1120 through 59-63-1160.
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