In what circumstances will a school security officer be considered a "special needs" security officer?

Seemingly acknowledging the state's vital interest in establishing and maintaining a safe educational environment, the minor then urges that the reasonable-suspicion standard, even if inapplicable to the conduct of teachers and administrators, should apply to encounters between students and school security officers. In holding that the reasonable-suspicion standard remains appropriate for such cases, he reasons, this court will not necessarily be committing itself to that standard "across the whole range of student encounters with teachers, principals, or other personnel." We decline the invitation to distinguish the power of school security officers over students from that of other school personnel, whose authority over student conduct may have been delegated to those officers. The same observation and investigation here could well have been undertaken by a teacher, coach, or even the school principal or vice-principal. If we were to draw the distinction urged by the minor, the extent of a student's rights would depend not on the nature of the asserted infringement but on the happenstance of the status of the employee who observed and investigated the misconduct. Of equal importance, were we to hold that school security officers have less authority to enforce school regulations and investigate misconduct than other school personnel, there would be no reason for a school to employ them or delegate to them duties relating to school safety. Schools would be forced instead to assign certificated or classified personnel to yard and hall monitoring duties, an expenditure of resources schools can ill afford. The title "security officer" is not constitutionally significant.³ (Cf. Ferguson v. City of Charleston (2001) 532 U.S. 67 [121 S.Ct. 1281, 1291-1292, 149 L.Ed.2d 205] [because the "primary purpose" of a program of testing obstetrics patients' urine for narcotics was "to generate evidence for law enforcement purposes . . . . this case simply does not fit within the closely guarded category of `special needs'" (fns.omitted)].) Therefore, we will not interfere in the method by which local school districts assign personnel to monitor school safety.