in this manner, the search of K.P.’s book bag appears no more intrusive than the search that occurs when a traveler brings a suit-ease into the passenger compartment of an airliner, an attorney carries her brief case into a courtroom, a commuter totes a shopping bag on the New York City subway, or a citizen carts a box of petitions to his Senator at the State Capital. In the Fourth Amendment context of special needs searches, examination of personal effects similar to the search of KP.’s book bag have passed constitutional muster for airports, courthouses, government buildings, and public transportation, with some of the highest courts in the land characterizing such searches as “minimally intrusive.” See, e.g., United States v. Aukai, 497 F.3d 955, 962 (9th Cir.2007) (en banc) (<HOLDING>); MacWade v. Kelly, 460 F.3d 260, 273 (2d
holding that a search of bags carried onto an airplane was minimally intrusive holding officers act of removing screws from vehicle to open a concealed compartment commonly used for drug transport was minimally intrusive did no damage to the vehicle and did not exceed the defendants consent to search holding the escalating intrusiveness of airport screen search from metal detector to pat down to emptying and searching pockets was minimally intrusive holding pat down at airport justified after officer observed bundle under suspects clothing near waist holding that a random visual and manual search of bags and packages carried onto the new york city subway was minimally intrusive