In Wofford v. Evans, the Fourth Circuit in an opinion by Judge Wilkinson, joined by Judge Williams and District Judge Titus, affirmed dismissal of the constitutional claims brought against Botetourt County School Board and various school officials in connection with its response to information that a student had brought a gun to school.
Judge Wilkinson wrote: "School officials must have the leeway to maintain order on school premises and secure a safe environment in which learning can flourish. Over-constitutionalizing disciplinary procedures can undermine educators’ ability to best attain these goals. Imposing a rigid duty of parental notification or a per se rule against detentions of a specified duration would eviscerate the ability of administrators to meet the remedial exigencies of the moment. The Constitution does not require such a result."