FourthAmendment.com notes this decision out of the Eastern District Virginia:
A 13-year-old male student was showing explicit pictures of a 14-year-old girl on his phone at school. The search of the phone by school officials was reasonable under T.L.O., and it led him to juvenile court. O.W. v. Sch. Bd. of the City of Va. Beach, 2023 U.S. Dist. LEXIS 25251 (E.D. Va. Feb. 14, 2023).
For those who may not know about the T.L.O case and SCOTUS ruling, you can find a summary here.