This is consistent with a similar case, "Santa Fe Independent School District v. Doe", involving prayer at a school football game. In this case, O'Connor joined the majority opinion that stated prayer at school football games violates the Establishment Clause. O'Connor was the first justice to articulate the "no endorsement" standard for the Establishment Clause. In "Lynch v. Donnelly", O'Connor signed onto a five-justice majority opinion holding that a nativity scene in a public Christmas display did not violate the First Amendment. She penned a concurrence in that case, opining that the crèche was not violative of the Establishment Clause because it did not express an endorsement or disapproval of any religion. According to law professor Jeffrey Rosen, "O'Connor was an eloquent opponent of intrusive group searches that threatened privacy without increasing security. In a 1983 opinion upholding searches by drug-sniffing dogs, she recognized that a search is most likely to be considered constitutionally reasonable if it is very effective at discovering contraband without revealing "innocent but embarrassing" information." Washington College of Law law professor Andrew Taslitz, referencing O'Connor's dissent in a 2001 case, said of her Fourth Amendment jurisprudence: "O'Connor recognizes that needless humiliation of an individual is an important factor in determining Fourth Amendment reasonableness." O'Connor once quoted the social contract theory of John Locke as influencing her views on the reasonableness and constitutionality of government action. In the 1990 and 1995 "Missouri v. Jenkins" rulings, O'Connor voted with the majority that district courts had no authority to require the state of Missouri to increase school funding in order to counteract racial inequality. In the 1991 "Freeman v. Pitts" case, O'Connor joined a concurring opinion in a plurality, agreeing that a school district that had formerly been under judicial review for racial segregation could be freed of this review, even though not all desegregation targets had been met. Law professor Herman Schwartz criticized these rulings, writing that in both cases "both the fact and effects of segregation were still present." In "McCleskey v. Kemp" in 1987, O'Connor joined a 5–4 majority that voted to uphold the death penalty for an African American man, Warren McCleskey, convicted of killing a white police officer, despite statistical evidence that black defendants were more likely to receive the death penalty than others both in Georgia and in the U.S. as a whole. In 1996's "Shaw v.