OH: School protocol to search unattended book bags made this search reasonable

“Based on the facts of this case, we hold that the school’s protocol requiring searches of unattended book bags—to determine ownership and whether the contents are dangerous—furthers the compelling governmental interest in protecting public-school students from physical harm. We further hold that the school employees’ search of the unattended book bag belonging to appellee, Whetstone High School student Joshua Polk, was limited to furthering that compelling governmental interest and was reasonable under the Fourth Amendment to the United States Constitution.” State v. Polk, 2017-Ohio-2735, 2017 Ohio LEXIS 810 (May 11, 2017).