The California Supreme Court reversed a decision of the court of appeal. The court held that the paucity of the record below made it impossible to determine whether or not the National Football League’s policy of conducting patdown searches of all persons attending NFL games was reasonable.

San Francisco 49ers season ticket holders Daniel and Kathleen Sheehan sued the 49ers after they were subjected to mandatory patdown searches as a condition of entry to all games during the 2005 season.