Good thing for them that consent is not required in circumstances where they have reasonable suspicion. Schools are granted a great deal of leeway by the courts to maintain safety and order.How can a middle school student meaningfully consent to a search by a school administrator?
There is zero level of awareness of a right to an alternative and their is the coercion of an authority figure in an enviromnent where the student has no right to leave.
Ideally, the schools would simply prohibit cell phones at school entirely since they cause a great deal of disruption. But, as CA has discovered, these devices have become so ubiquitous that even the courts are more often seeing them as less a luxury and more as a necessity.