Gillard v. Schmidt, 579 F.2d 825, 828 (3rd Cir.)

The ACLU Handbook on the Rights of Teachers:

"An anonymous cartoon had appeared in a local newspaper ridiculing the
financial and personnel policies of the Fair Lawn, New Jersey, Board of
Education by depicting the board members a poker players, apparently
gambling away emplyees' salaries and jobs. Suspecting the guidance
counselor as the offending cartoonist, a board member entered the
guidance counselor's school at night, found a janitor with a pass key,
directed him to unlook the door to the guidance counselor's suite, and
observing a slightly opened drawer in the guidance counselor's disk,
pulled it completely open, revealing copies of the cartoon. The court
ruled that this action violated the guidance counselor's Fourth
Amendment rights."