Law School Case Brief
Chandler v. Miller - 520 U.S. 305, 117 S. Ct. 1295 (1997)
To be reasonable under the Fourth Amendment, a search ordinarily must be based on individualized suspicion of wrongdoing. But particularized exceptions to the main rule are sometimes warranted based on special needs, beyond the normal need for law enforcement. When such special needs--concerns other than crime detection--are alleged in justification of a Fourth Amendment intrusion, courts must undertake a context-specific inquiry, examining closely the competing private and public interests advanced by the parties. In limited circumstances, where the privacy interests implicated by the search are minimal, and where an important governmental interest furthered by the intrusion would be placed in jeopardy by a requirement of individualized suspicion, a search may be reasonable despite the absence of such suspicion.
In 1990, the state of Georgia enacted a statute which required that each candidate seeking to qualify for nomination or election to designated state offices certify that (1) the candidate, within 30 days prior to qualifying, had submitted to a urinalysis test for marijuana, cocaine, opiates, amphetamines, and phencyclidines, and (2) the results of such test were negative. The candidate could provide the test specimen at a laboratory approved by the state or at the office of the candidate's personal physician. Once a urine sample was obtained, a state-approved laboratory determined whether any of the specified illegal drugs were present and prepared a certificate reporting the test results to the candidate. In 1994, three candidates for state offices which were covered by the statute filed an action in the United States District Court for the Northern District of Georgia against the governor of Georgia and two other state officials involved in the administration of the statute. The candidates, who requested declaratory and injunctive relief barring enforcement of the statute, alleged that the drug tests required by the statute violated their rights under provisions including the Federal Constitution's Fourth Amendment. The District Court denied the candidates' motion for a preliminary injunction. The candidates apparently submitted to the drug tests, obtained the required certificates, and appeared on the ballot in the 1994 election. After the election, the District Court entered final judgment for the state officials. On appeal, the United States Court of Appeals for the Eleventh Circuit, in affirming, expressed the view that with respect to the Fourth Amendment, the state's interests outweighed the privacy intrusion caused by the statute's required certification.
Was Ga. Code Ann. § 21-2-140, a statute which required candidates for designated state office to certify that they had taken a drug test and obtained negative results, unconstitutional violating the Fourth Amendment?
The Court held that Georgia's requirement that candidates for state office pass a drug test was outside the category of constitutionally permissible suspicionless searches. The Court emphasized that the proffered special need for drug testing must be substantial--important enough to override the individual's acknowledged privacy interest, sufficiently vital to suppress the Fourth Amendment's normal requirement of individualized suspicion. The Court found that Georgia failed to show, in justification of Ga. Code Ann. § 21-2-140, a special need of that kind. Notably lacking in respondent officials' presentation was any indication of a concrete danger that demanded departure from the Fourth Amendment's main rule. The statute was not needed and could not work to ferret out lawbreakers, and officials barely attempted to support the statute on that ground. However well meant, the candidate drug test Georgia devised diminished personal privacy for a symbol's sake; state action that is prohibited by the Fourth Amendment. Where, as in this case, public safety was not genuinely jeopardized, the Fourth Amendment precluded a suspicionless search, no matter how conveniently arranged.
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