Marijuana, privacy, evidence, due process, search, Fourth Amendment, Fourteenth Amendment.

J.M.A., a juvenile, appeals a lower court's decision to place him in a state correctional facility. State officials placed J.M.A. with a foster family. His foster mother became concerned about his activities and searched his bedroom. She discovered and confiscated a pipe she believed was used for smoking marijuana. She performed another search a short time later and discovered a bag of marijuana in J.M.A.'s coat. The foster mother notified state officials, and J.M.A was placed in a juvenile detention center. J.M.A.'s attorney petitioned the court to suppress the evidence discovered by the foster mother. The attorney argued the foster parents were agents of the state and subject to the established restrictions for performing an evidence search.

A trial court denied J.M.A.'s motion to suppress the evidence discovered by his foster mother. The court also ruled J.M.A. a delinquent and ordered him placed in a state correctional facility. J.M.A. now appeals.

J.M.A. loses. The Alaska Supreme Court affirmed the trial court's ruling. The supreme court ruled that J.M.A.'s foster parents could not be considered agents of the state. Therefore, the court ruled, the foster parents were not subject to standard search guidelines. The supreme court also ruled it could find no reversible error in the lower court's handling of the case.