seizure, should be effectuated and no evidence resulting from such a search and seizure should be considered unless there has been a sufficient showing of a particularized and focused suspicion, amounting to probable cause, that the place or individual to be searched was involved in criminal activity. Kyllo v. United States, 533 U.S. 27, 31, 121 S.Ct. 2038, 2041, 150 L.Ed.2d 94, 100 (2001); See Generally, Wayne LaFave, Search And Seizure: A Treatise On The Fourth Amendment, 2 Search & Seizure § 3.1(a). From its inception, “the Fourth Amendme 4, 122 S.Ct. at 2559, 153 L.Ed.2d at 744 (urine testing of students engaged in extracurricular activities to prevent health and safety risks of drug use); Vernonia School Dist. 47J, 515 U.S. at 661-64, 115 S.Ct. at 2394-2396, 132 L.Ed.2d at 579-82 (<HOLDING>). These changes do not indicate, however, that
holding the error harmless in light of the overwhelming evidence of guilt holding that school district policy requiring that students obtain the review and approval of school officials prior to distributing any written material violated free speech rights of students holding that school districts requirement that all students who wished to participate in interscholastic sports submit to random urinalysis testing was reasonable in light of the overwhelming interest in ensuring that youth are drug free recognizing application of sovereign immunity to school districts holding that the admission of a family photo was harmless error in light of the overwhelming evidence in support of the conviction