This analysis applies to police liaison officers as well. See Coronado v. State (Tex.Ct.App. 1991), 806 S.W.2d 302, rev'd on other grounds (Tex.Crim.App. 1992), 835 S.W.2d 636; Cason. v. Cook (8th Cir. 1987), 810 F.2d 188. Although several decisions have allowed student searches under the reasonable suspicion standard where police have participated in the search (see Martens v. District No. 220, Board of Education (N.D. Ill. 1985), 620 F. Supp. 29; Cason v. Cook (8th Cir. 1987), 810 F.2d 188), these decisions have stressed that police involvement in the searches was minimal.
The trial judge denied the motion. Appellant later entered a plea of nolo contendere and contested the legality of the search on appeal. The Court of Appeals affirmed. Coronado v. State, 806 S.W.2d 302, 303 (Tex.App. — Texarkana 1991). We granted appellant's petition for discretionary review to consider the reasonableness of the search of appellant's vehicle by the school officials.
Furthermore, in finding the T.L.O. standard applicable, the Murray Court referenced cases from other jurisdictions in which courts concluded that T.L.O.'s standard applied where "a police officer works in conjunction with school officials," in varying degrees, to maintain a safe and educational environment. Cason, 810 F.2d at 192; see also Martens v. District No. 220, Bd. of Educ., 620 F. Supp. 29 (N.D.Ill. 1985); Coronado v. State, 806 S.W.2d 302 (Tex.App. 1991), rev'd on other grounds, 835 S.W.2d 636 (Tex.Crim.App. 1992). The application of T.L.O. in situations where law enforcement acts in conjunction with school officials is based on the premise that
Therefore, we hold that the search of Murray's book bag was conducted by a school official. See Cason v. Cook, 810 F.2d 188, 192 (8th Cir. 1987) ("At most . . . this case represents a police officer working in conjunction with school officials."); see also Martens v. District No. 220, Bd. of Educ., 620 F. Supp. 29 (N.D.Ill. 1985); Coronado v. Texas, 806 S.W.2d 302 (Tex.App. 1991), rev'd on other grounds, 835 S.W.2d 636 (Tex.Crim.App. 1992). Consequently, we review the search in light of New Jersey v. T.L.O., 469 U.S. 325, 83 L.Ed.2d 720 (1985), wherein the United States Supreme Court examined the legality of a school official's search of a student's purse.