As high-profile incidents of school violence appear to become more frequent and severe, public perception has deteriorated to the point where many citizens believe that schools are unsafe and administrators lack the power to control student activity. In their efforts to promote a safe learning environment, many school administrators have attempted to create strict guidelines concerning the power of school personnel to prevent illegal and unsafe activity from taking place at school. However, as administrators devise the rules by which to implement these standards, they are given little guidance by the Supreme Court regarding the application of the Fourth Amendment to a school setting. This Note examines the Court's reluctance to provide a clear directive to school districts as to the proper limits of students' Fourth Amendment protections while at school. The author examines the limited precedent of the Supreme Court, as well as the reasoning put forth by various state courts, to reveal the wide range of factors relied upon to differing degrees by courts in determining the constitutionality of a school search. The Note calls for the Court to clarify the constitutional boundaries of school searches and provide administrators with an adequate standard on which to base school policies.