The Sixth Circuit affirmed summary judgment for all defendants. Doctrinally, the opinion is most important for one novel holding: it is the court’s first published decision to define and analyze Fourth Amendment “seizures” in the public-school context. The court:

• adopts a definition of when a student is “seized” at school (borrowing from the Tenth and Seventh Circuits); and
• extends the T.L.O. reasonable-suspicion framework (long applied to school searches) to school seizures as well.

At the same time, the decision reinforces:

• the relatively deferential standard applied to school disciplinary proceedings under procedural due process;
• the **extremely high bar** for substantive due process challenges to school discipline; and
• the breadth of Michigan governmental immunity for school districts and their employees.

II. Factual and Procedural Background

A. The Context: A Recent Mass Shooting and Heightened Sensitivity

During the 2021–22 school year, H.H., an eighth grader at Cass City Public Schools, allegedly made gun-related comments in science class on December 6, 2021—about a week after the Oxford High School shooting in Oakland County, Michigan, in which Ethan Crumbley killed four students and wounded seven others. The Oxford shooting is explicitly recognized by the panel as the deadliest high-school shooting in Michigan history and forms a crucial backdrop for the perceived threat and the school’s reaction.

B. The Alleged Threat

Multiple students recounted that H.H. made statements suggesting access to, or the possibility of bringing, a gun to school. Among the variations reported:

• that H.H. “said that he had guns and that if he brought them to the school, nobody would do anything about it”;
• that he said something about bringing a “fake but metal gun” to school;
• that he said something about having a gun in his bag; and
• that he was “thinking about bringing a gun to school.”

Student R.B., who reported feeling unsafe, stated that H.H. had previously commented about having access to guns. She texted her mother, Stacey Bliss, a school board member, who then contacted Superintendent Allison Zimba. Another parent also called the principal, William Hartzell, with similar concerns.

C. The Office Questioning and Search

The superintendent, principal, and school behavioral officer, Donald Markel, involved Michigan State Police Lieutenant Brian McComb. H.H., who was already waiting in the office to be picked up by his grandmother, was interviewed by Zimba, Markel, and Lt. McComb.

Key facts about this interaction:

• H.H. was not advised of Miranda rights, nor told a criminal investigation was underway.
• The questioning lasted about ten minutes; H.H. denied making threats or having a gun.
• H.H. agreed to a search: he removed sweatshirt and shoes; he states he was told to raise his shirt and pull his waistband out; school officials searched his backpack; Markel searched his locker.
• No firearm was found.

Later that day, the Michigan State Police searched the Halasz home, finding only a gun safe, no weapons. The police concluded H.H. “may have been misunderstood” and “did not pose any immediate danger,” but recommended he not remain in school.

D. Disciplinary Points and Expulsion Recommendation

The district used a point-based disciplinary system. H.H. already had 7 points. The administration assigned 8 more for “gross misbehavior” based on threatening remarks, reaching 15 points and triggering an expulsion referral.

• On December 7, 2021, the administration referred H.H. to the Board for an expulsion hearing.
• Superintendent Zimba sent the family written notice, recommending a 180-day expulsion and setting a December 13 hearing date.

E. The Expulsion Hearing

At the Board hearing:

• H.H. attended with his parents and was represented by counsel.
• Board member Bliss was present but recused herself from voting.
• The Board applied “Mandatory 7 Factors,” including age, disciplinary history, disability, seriousness, safety risk, restorative practices, and lesser interventions.
• Superintendent Zimba did not disclose to the Board the State Police conclusion that H.H. was not an “immediate danger.”
• The Board expelled H.H. for 180 days based on finding that he made threatening comments (i.e., said he had a gun or might bring one).

F. The Lawsuit and District Court Ruling

The Halaszes brought:

• § 1983 claims for:
  • unconstitutional search (Fourth Amendment);
  • unconstitutional seizure (Fourth Amendment);
  • procedural due process violation (Fourteenth Amendment);
  • substantive due process violation (Fourteenth Amendment).
• State-law claims under Michigan law for:
  • negligence; and
  • intentional infliction of emotional distress (IIED).

The district court granted summary judgment to all defendants. The parents appealed, and the Sixth Circuit reviewed the decision de novo under the familiar Rule 56 standard (citing Puskas, Hrdlicka, and Palma).

III. Summary of the Sixth Circuit’s Decision

The court (Judge Mathis, joined by Judges Siler and Kethledge) affirmed in full. The principal holdings can be summarized as follows:

1. Fourth Amendment – Search: The search of H.H.’s person, backpack, and locker was reasonable in scope under New Jersey v. T.L.O.. The parents did not challenge the initial justification; the court held the specific intrusions were proportionate to the goal of finding a possible weapon.
2. Fourth Amendment – Seizure (New Law):
   • The court, for the first time in a published opinion, defined a Fourth Amendment “seizure” of a student in a public school and adopted a test.
   • A student is seized when a school official curtails the student’s freedom of movement in a way that “significantly exceeds that inherent in everyday, compulsory attendance” (following the Tenth Circuit’s Couture and Seventh Circuit’s Wallace).
   • The court then adopted the T.L.O. reasonable-suspicion framework for evaluating such seizures: they must be justified at inception by reasonable suspicion and reasonable in scope.
   • Applying that test, the 30-minute office detention and questioning of H.H. were held to be reasonable.
3. Procedural Due Process: H.H. received all process constitutionally required for school expulsion. He had timely written notice, representation by counsel, and an opportunity to contest the evidence before an impartial Board. Alleged nondisclosure of the police’s “no immediate danger” conclusion did not invalidate the process because the expulsion rested on the threatening statement, not on actual weapon possession.
4. Substantive Due Process: The 180-day expulsion was neither conscience-shocking nor irrational under the circumstances, and therefore did not violate substantive due process. The panel applied the Sixth Circuit’s strict standard from Seal v. Morgan: a school-discipline substantive due process claim succeeds only in the “rare case” where no rational relationship exists between the offense and the punishment.
5. Qualified Immunity: Because the plaintiffs failed to establish any underlying constitutional violation, all individual defendants were entitled to qualified immunity. Any derivative Monell claim against the district also failed for lack of a constitutional violation.
6. State-Law Tort Claims:
   • The school district, as a governmental agency performing a governmental function (operation of a public school), was immune from tort liability under the Michigan Governmental Tort Liability Act (GTLA).
   • The individual defendants were immune from negligence claims because the plaintiffs produced no evidence of “gross negligence” under Michigan law.
   • The individual defendants were likewise immune from IIED claims because there was no evidence they acted outside the scope of their authority, in bad faith, or without discretion as required under Odom v. Wayne County.

IV. Detailed Analysis

A. Fourth Amendment Search: Applying T.L.O. and Safford

1. Legal Framework

The court reiterates settled principles of student Fourth Amendment law:

• The Fourth Amendment, incorporated against the states through the Fourteenth Amendment, protects against unreasonable searches (Maryland v. Pringle).
• Students retain constitutional rights at school; they do not “shed their constitutional rights at the schoolhouse gate” (Vernonia Sch. Dist. 47J v. Acton, quoting Tinker).
• However, those rights are adjusted “for children in school” (Vernonia), leading to a specialized standard of reasonableness.

Under New Jersey v. T.L.O., the court applies a two-step test:

1. Justification at inception: Was there a “moderate chance of finding evidence of wrongdoing?” (Safford Unified Sch. Dist. No. 1 v. Redding interprets this as akin to reasonable suspicion.)
2. Scope of the search: Was the search reasonably related to its objectives and “not excessively intrusive in light of the age and sex of the student and the nature of the infraction” (T.L.O.)?

2. Application to H.H.’s Search

Importantly, the Halaszes did not dispute that the search was justified at inception, likely recognizing that multiple student reports of possible gun possession or threats, in the shadow of a recent mass shooting, easily cleared the reasonable-suspicion bar.

The only challenge was to scope. The court evaluated:

• H.H. being asked to remove sweatshirt and shoes;
• H.H. being directed to lift his shirt and pull his waistband forward;
• the search of his backpack by the superintendent; and
• the search of his locker by the behavioral officer.

Given the purpose—determining whether H.H. had a firearm—these locations were plainly places where a gun could be hidden. The intrusiveness was comparatively modest:

• No physical touching of H.H. by officials;
• No requirement to remove pants, underwear, or expose genitals;
• No strip search comparable to the unconstitutional search in Safford (where a 13-year-old girl was made to shake out bra and underwear to search for pills).

Thus, the court held the search was reasonable in scope, explicitly distinguishing the more invasive conduct condemned in Safford.

3. Rejection of the Miranda and Policy-Based Arguments

The parents argued the search was unreasonable because:

• H.H. was not given Miranda warnings; and
• school policy requiring reasonable efforts to contact parents before police questioning was not followed.

The court rejected both as legally irrelevant to the Fourth Amendment analysis:

• Miranda rights regulate the admissibility of custodial statements under the Fifth Amendment; they do not define the reasonableness of physical searches under the Fourth Amendment.
• Violation of internal policy (not contacting parents) does not, by itself, make a search constitutionally unreasonable. The Constitution sets a floor that school policies may exceed, but failure to follow policy is not automatically a constitutional violation.

This reinforces a familiar principle: federal constitutional standards govern § 1983 liability, not internal guidelines or best practices, however important those may be for good administration or state-law issues.

B. Fourth Amendment Seizure: New Sixth Circuit Standard for Students

1. Filling a Doctrinal Gap

The court notes that it had “never decided in a published opinion whether or how the Fourth Amendment’s guarantee against unreasonable seizures applies in the public-school context” (citing Johnson ex rel. X.M. v. Mount Pleasant Pub. Schs.). This case becomes the vehicle to articulate that framework.

2. Defining a “Seizure” in School

Outside school, the Supreme Court’s general standard from California v. Hodari D. applies: a person is seized if a reasonable person would not feel free to leave. But in school:

• Students are already not free to come and go at will during the school day (Vernonia, Couture).
• Restricting students’ freedom of movement is “a sine qua non of the educational process” (Wallace).

Therefore, the Sixth Circuit crafts a school-specific test, aligning with the Tenth Circuit (Couture v. Bd. of Educ. of Albuquerque Pub. Schs.):

A public-school official “makes a Fourth Amendment seizure of a student when the official limits ‘the student's freedom of movement’ in a manner that ‘significantly exceed[s] that inherent in everyday, compulsory attendance.’”

This definition accommodates the reality of school discipline and supervision while recognizing that more extreme restraints (e.g., prolonged isolation, locked rooms, law-enforcement-style detention) can constitute constitutional “seizures.”

3. Adopting T.L.O.’s Reasonable-Suspicion Standard for Seizures

The court then addresses how to judge the reasonableness of such a seizure. It chooses to extend the familiar T.L.O. framework—which historically applies to searches—to seizures of students:

1. The seizure must be justified at its inception by reasonable grounds for believing the student has violated a law or school rule; and
2. The seizure’s scope (including duration and intrusiveness) must be reasonably related to the circumstances justifying it in the first place.

In doing so, the Sixth Circuit joins the 3rd, 4th, 5th, 9th, 10th, and 11th Circuits (including Gray v. Bostic, Shuman, Wofford, Doe v. Hawaii Dep’t of Educ., Hassan, and Edwards) that have applied a similar standard to school seizures.

4. Application to the Detention of H.H.

The court assumes—without definitively deciding—that H.H. was “seized” when he was brought to and held in the office. Even under that assumption, it finds the seizure reasonable:

• Justification at inception: Multiple student complaints of a gun-related threat, in a context of heightened fear after a mass shooting, provided clear reasonable suspicion that H.H. may have violated rules relating to weapons or threats.
• Scope and duration: H.H. was held for roughly thirty minutes for questioning and a search aimed at determining whether he was armed. The court, citing Wofford, characterizes this as “no longer than necessary” to investigate and confirm he had no gun.

Once again, the court rejects the relevance of the absence of Miranda warnings or any failure to disclose that law enforcement was involved. Those concerns relate to Fifth Amendment and criminal-procedure doctrines, not to Fourth Amendment seizure reasonableness.

5. Doctrinal Impact

This segment of the opinion is the primary new precedent:

• It creates a **controlling Sixth Circuit standard** for evaluating student seizures in public schools.
• It explicitly harmonizes Sixth Circuit law with the majority of other circuits on this question, promoting uniformity.
• It tells school officials they may impose short-term, investigation-related detentions based on reasonable suspicion, provided the duration and conditions are proportionate to the suspected infraction.

Unresolved but implicated issues for future litigation include:

• What duration or conditions of confinement “significantly exceed” those inherent in ordinary school discipline (e.g., extended in-school suspensions, use of physical restraints, lockdown in rooms)?
• How the presence and primary role of law enforcement (as opposed to school officials) might affect both the seizure threshold and whether a stricter probable-cause standard might apply in some circumstances.
• At what point an investigative detention becomes so custodial that Miranda rights are required for admissibility of statements in criminal proceedings (though not at issue here as a civil case).

C. Procedural Due Process: Minimal Constitutional Floor for School Expulsions

1. Governing Principles

Under the Fourteenth Amendment, procedural due process requires that the state provide adequate procedures when depriving individuals of life, liberty, or property (Reed v. Goertz, Mullane).

In the school setting:

• Goss v. Lopez recognizes that students have a property interest in public education created by state law.
• Goss and Sixth Circuit precedent (Newsome v. Batavia Loc. Sch. Dist., Heyne v. Metro. Nashville Pub. Schs.) require at least:
  • oral or written notice of charges;
  • explanation of the evidence if the student denies the charges; and
  • an opportunity to present the student’s side of the story to an impartial decisionmaker.

2. Was Process Adequate Here?

The Sixth Circuit finds the minimum requirements clearly satisfied:

• Written notice was sent on December 7, outlining the recommendation for 180-day expulsion and setting a December 13 hearing date.
• At the hearing, H.H. was represented by counsel, accompanied by his parents.
• The Board explained the witness statements and allowed H.H. to contest them through counsel.

This is entirely consistent with what Goss and Newsome require.

3. Withheld Evidence: State Police Assessment

The parents’ central due-process argument was that Superintendent Zimba withheld from the Board the State Police conclusion that H.H. did not pose an “immediate danger” and may have been misunderstood. They argued this deprived H.H. of a meaningful and fair hearing.

The Sixth Circuit rejects this argument for two main reasons:

1. Basis of the Expulsion: The Board expelled H.H. for making a threatening statement—saying he had a gun or would bring one—not for actual gun possession or immediate physical danger. The police conclusion addressed imminent physical danger and actual possession; it did not negate the evidence that he made the statements.
2. Independent evaluation of the same record: The Board had access to the same student statements that the police had reviewed. The police concluded H.H. “may” have been misunderstood; the Board, weighing the same conflicting recollections, reached its own conclusion that he indeed made the threatening remarks. Differing interpretations do not equate to procedural unfairness.

The court also reiterates the core concern of procedural due process in school discipline: prevention of “unfair or mistaken findings of misconduct and arbitrary exclusion from school” (Heyne, quoting Goss). Here, the Board’s finding that H.H. engaged in threatening speech was supported by multiple student accounts and thus was not “clearly mistaken.”

4. Alleged Board Bias and Bliss’s Role

The parents additionally argued the Board was biased because:

• Board members reviewed H.H.’s disciplinary record before determining guilt; and
• Board member Bliss, who had reported concerns as a parent, attended the hearing.

The court applies the presumption of impartiality recognized in Doe v. Miami Univ. and Withrow v. Larkin, holding:

• Awareness of a student’s disciplinary record does not, by itself, show actual bias; no case law suggests otherwise.
• Bliss recused herself from voting and deliberations. Even had she not, Miami Univ. holds that combining investigative and adjudicative roles does not automatically violate due process absent concrete evidence of bias.

Because plaintiffs presented no specific facts showing bias, the presumption of impartiality stands, and the procedural due process challenge fails.

D. Substantive Due Process: High Threshold for Attacking School Discipline

1. Legal Standard

Substantive due process “bars certain government actions regardless of the fairness of the procedures used” (County of Sacramento v. Lewis). The Sixth Circuit, following Guertin v. Michigan and Johnson v. City of Saginaw, describes several formulations:

• Conduct that “shocks the conscience” or offends the “decencies of civilized conduct”;
• Actions that are “so brutal and so offensive to human dignity”;
• Conduct that is “extremely irrational” or lacks any factual basis; or
• Action that is arbitrary or capricious, lacking a rational relationship to a legitimate governmental objective.

In the specific context of school discipline, the court invokes Seal v. Morgan:

A substantive due process claim will succeed only in the rare case when there is no rational relationship between the punishment and the offense.

2. Application to the 180-Day Expulsion

The parents argued the expulsion “shocks the conscience” and is arbitrary because:

• H.H. never possessed a weapon;
• the State Police found he posed no immediate threat; and
• yet he was expelled for 180 days.

The court holds:

• The expulsion does not approach the sort of “brutal” or “offensive to human dignity” conduct typically required by substantive due process case law.
• There is a clear rational connection between the offense—threatening remarks about having or bringing a gun to school—and the penalty, especially in the immediate wake of a fatal school shooting.
• That H.H. ultimately did not have a gun and was not an “immediate danger” does not make the discipline irrational or conscience-shocking.

The court emphasizes the narrowness of substantive due process protections in this domain, warning against turning “run-of-the-mill” disciplinary disputes into constitutional torts.

E. Qualified Immunity and Monell Liability

1. Qualified Immunity

Applying District of Columbia v. Wesby, the court reiterates the two-step qualified immunity inquiry:

1. Did the official violate a federal statutory or constitutional right?
2. Was that right clearly established at the time?

The burden rests on the plaintiff to overcome immunity (Mosier v. Evans).

Because the court concluded on the merits that no constitutional violation occurred at all, the first prong fails; the analysis ends there. All individual defendants are therefore shielded by qualified immunity from § 1983 damages.

2. Monell Claim Against the School District

In a brief but important footnote, the court addresses any implied Monell claim against the district (alleging liability based on an official policy or custom). Citing Martinez v. Wayne County, the panel underscores that:

“There can be no liability under Monell without an underlying constitutional violation.”

Because all constitutional claims failed, any Monell theory against the district necessarily fails as well.

F. Michigan State-Law Claims and Governmental Immunity

1. Immunity of the School District

Under the Michigan Governmental Tort Liability Act (GTLA), Mich. Comp. Laws § 691.1407(1), governmental agencies are immune from tort liability when engaged in a “governmental function,” absent narrow exceptions not applicable here.

• “Governmental function” means activities mandated or authorized by law (§ 691.1401(b)).
• A school district is a governmental agency (§ 691.1401(a), (e)).
• Michigan courts (e.g., Stringwell v. Ann Arbor Pub. Sch. Dist.) explicitly recognize that operating a public school is a governmental function.

Because Cass City Public Schools was engaged in operating a public school, the district is absolutely immune from tort liability for the negligence and IIED claims.

2. Negligence Claims Against Individual Defendants

For negligence claims, § 691.1407(2) grants immunity to government employees if:

1. They were acting or reasonably believed they were acting within the scope of their authority;
2. The employer was engaged in a governmental function; and
3. Their conduct did not amount to gross negligence—defined as “conduct so reckless as to demonstrate a substantial lack of concern for whether an injury results” (§ 691.1407(8)(a)).

The first two elements are undisputed: the officials were performing school-related duties, and the district was engaged in operating a public school.

On gross negligence, while Michigan law generally leaves this to a jury (Wood v. City of Detroit), a plaintiff must produce evidence sufficient to create a genuine dispute of material fact. The Sixth Circuit notes that the Halaszes offered only a conclusory assertion, with no record evidence that the defendants’ conduct was so reckless as to show a substantial lack of concern for injury.

Accordingly, the individual defendants receive immunity from negligence liability.

3. Intentional Infliction of Emotional Distress (IIED)

For intentional torts, Michigan applies a different immunity test, articulated in Odom v. Wayne County. An employee is immune if:

1. He or she acted or reasonably believed he or she was acting within the scope of authority;
2. The actions were undertaken in good faith (i.e., not with malice); and
3. The conduct involved the exercise of discretion or judgment.

Again, the plaintiffs offered no evidence that:

• the officials acted outside their roles as administrators or board members;
• they acted with malice or bad faith rather than in response to a perceived safety threat; or
• their actions were non-discretionary.

Because the plaintiffs failed to raise a triable issue on any of these elements, the officials are immune from the IIED claims as well.

V. Key Concepts Simplified

1. Search vs. Seizure in School

• Search: When school officials inspect a student’s body, clothing, bag, or locker to find evidence—e.g., asking a student to lift his shirt, searching a backpack, or checking a locker.
• Seizure: When officials restrict a student’s freedom of movement—e.g., making the student stay in the office or a room, or not allowing the student to leave—beyond normal classroom or school-day control.

2. Reasonable Suspicion and Scope in Schools

In schools, officials do not need “probable cause” to search or briefly detain a student. Instead:

• Reasonable suspicion means a “moderate chance” the student broke a rule or law, based on specific facts (like credible student reports).
• Scope means the seriousness and intrusiveness of the search or detention must be proportionate to what is suspected and to the student’s age and gender.

3. Procedural vs. Substantive Due Process

• Procedural due process asks: Did the school follow fair procedures (notice, explanation of evidence, chance to respond) before expelling or suspending a student?
• Substantive due process asks: Is the government’s action so irrational, extreme, or abusive that it violates basic constitutional norms, even if good procedures were used?

4. Qualified Immunity

Qualified immunity protects individual public officials from being sued for money damages unless:

1. They actually violated the Constitution or a federal law; and
2. It was “clearly established” at the time that what they did was unlawful—so that any reasonable official would have known it.

If there is no underlying constitutional violation, the official automatically wins on qualified immunity.

5. Michigan Governmental Tort Immunity

• Government agencies (like school districts) are generally not liable for negligence or other torts when performing government functions, like running schools.
• Employees are personally protected unless they act with gross negligence (extreme carelessness showing almost no concern for harm) or act outside their authority or in bad faith with respect to intentional torts.

VI. Broader Implications and Likely Impact

A. Fourth Amendment Seizure Doctrine in the Sixth Circuit

The most significant doctrinal development is the clear articulation of when a student is seized and how to evaluate such seizures:

• School officials now have clear authority, within the Sixth Circuit, to briefly detain students—such as pulling them from class or holding them in the office—for investigative questioning based on reasonable suspicion, so long as:
  • the restraint goes no further than reasonably needed; and
  • the duration is reasonably short and tied to the investigative purpose.
• Litigants will focus heavily on whether a particular restriction “significantly exceeds” ordinary school control. Length, use of physical restraint, involvement of law enforcement, and conditions of confinement will all be key evidence.

For students and parents, this opinion narrows potential Fourth Amendment claims to the more extreme forms of detention (for example, prolonged seclusion, handcuffing by school resource officers, or detention that resembles a criminal arrest) and confirms that routine office detentions for investigations are often constitutionally sound.

B. Interactions Between School Officials and Law Enforcement

The presence of Lt. McComb (a State Police officer) in H.H.’s questioning and search underscores the increasingly blurred line between school discipline and law enforcement. While the court’s analysis does not distinguish sharply between school officials and police for purposes of the search/seizure inquiry, future cases may test:

• whether actions led or dominated by police (e.g., arrest, handcuffing) in a school setting are governed by ordinary criminal law standards (probable cause, Miranda) rather than the relaxed T.L.O. standard; and
• when, if ever, parental-notification requirements or school policies translate into constitutional constraints when police are involved.

Halasz makes clear that violation of school policy alone is not a federal constitutional violation, but it leaves space for state-law or administrative remedies for such violations.

C. Deference to School Discipline in Due Process Claims

The opinion reinforces:

• the low procedural bar set by Goss and its progeny for expulsions—written notice, explanation, opportunity to respond, and an impartial decisionmaker; and
• the high substantive bar to recasting disagreements over disciplinary outcomes as constitutional violations.

Boards may rely on:

• student testimony, including conflicting accounts;
• their own assessments of credibility; and
• contextual factors such as recent violence or community fears.

They are not required to treat law-enforcement conclusions as binding or to disclose every nuance of those investigations, so long as the decision is not an arbitrary outlier stripped of factual foundation.

D. Michigan Governmental Immunity: A Difficult Hurdle for Plaintiffs

For Michigan practitioners, Halasz is a pointed reminder that:

• School districts are largely insulated from tort liability arising from disciplinary actions; and
• Claims against individual school personnel for negligence or intentional torts will typically be dismissed at summary judgment absent concrete evidence of gross negligence or bad faith.

Plaintiffs who hope to survive summary judgment must do more than allege unfairness or emotional harm; they must marshal specific facts showing either:

• extreme recklessness in the face of obvious risk; or
• malicious or bad-faith conduct that falls outside the scope of school officials’ duties.

VII. Conclusion

Halasz v. Cass City Public Schools is a significant decision in the Sixth Circuit’s school-law jurisprudence. The opinion:

• Establishes, for the first time, a published framework for Fourth Amendment “seizures” of students in public schools, defining when a seizure occurs and applying the T.L.O. reasonable-suspicion standard to evaluate it.
• Reaffirms that relatively limited, safety-driven searches of students’ persons and belongings—especially in the wake of credible threat reports—are likely to be found reasonable under the Fourth Amendment.
• Clarifies that the constitutional floor for procedural due process in school expulsions remains modest, and that substantive due process challenges will succeed only in extraordinary, irrational, or conscience-shocking cases.
• Confirms the protective reach of qualified immunity for individual school officials and of Michigan’s GTLA for school districts and employees, absent clear evidence of constitutional violations or grossly negligent / bad-faith conduct.

Against the backdrop of increasing concern about school shootings and threats, Halasz signals that the Sixth Circuit will grant considerable leeway to school administrators who act on reasonable suspicion to investigate and respond to potential dangers, while still insisting on basic procedural safeguards and proportionality in the measures used.