Chandler v. Miller - AbsoluteAstronomy.com

Chandler v. Miller, was a case before the United States Supreme Court concerning the Constitutionality under the Fourth Amendment of a state statute requiring drug tests of all candidates for certain state offices.

Statute

In 1990, Georgia

Georgia (U.S. state)

Georgia is a state located in the southeastern United States. It was established in 1732, the last of the original Thirteen Colonies. The state is named after King George II of Great Britain. Georgia was the fourth state to ratify the United States Constitution, on January 2, 1788...

enacted a statute which required candidates for designated state office to certify that they had taken a drug test

Drug test

A drug test is a technical analysis of a biological specimen – for example urine, hair, blood, sweat, or oral fluid / saliva – to determine the presence or absence of specified parent drugs or their metabolites...

and obtained negative results. The candidate could provide test specimen at a laboratory

Laboratory

A laboratory is a facility that provides controlled conditions in which scientific research, experiments, and measurement may be performed. The title of laboratory is also used for certain other facilities where the processes or equipment used are similar to those in scientific laboratories...

approved by the state or at the office of the candidate's personal physician

Physician

A physician is a health care provider who practices the profession of medicine, which is concerned with promoting, maintaining or restoring human health through the study, diagnosis, and treatment of disease, injury and other physical and mental impairments...

. Once a urine sample was obtained, a state-approved laboratory determined whether any of the specified illegal drugs

DRUGS

Destroy Rebuild Until God Shows are an American post-hardcore band formed in 2010. They released their debut self-titled album on February 22, 2011.- Formation :...

were present and prepared a certificate reporting the test results to the candidate.

Facts

In 1994, three candidates for such state offices statute filed an action in District Court against the governor of Georgia and two other state officials involved in the administration of the statute, requesting declaratory and injunctive relief barring enforcement of the statute. They alleged that the drug tests required by the statute violated their rights under provisions including the Federal Constitution's Fourth Amendment.

District court

The District Court denied the candidates' motion for a preliminary injunction. After the candidates submitted to the drug tests, obtained the required certificates, and appeared on the ballot in the 1994 election, the District Court entered final judgment for the state officials.

Eleventh Circuit

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 (73 F.3d 1543).

Opinion of the Court

On certiorari, Ginsburg, joined by Stevens, O'Connor, Scalia, Kennedy, Souter, Thomas, and Breyer reversed.

Reasoning

The Court noted that while the Fourth Amendment generally prohibits officials from conducting search and seizures without individualized suspicion, there does exist a "closely guarded" category of permissible suspicionless searches and seizures.

However, the Court held that the statute's drug-testing requirement did not fit within this category.

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. In addition to Georgia's failure to provide evidence of a drug problem among its state officials, the Court concluded that even if such a problem did exist, the affected officials would likely not perform the kind of high-risk, safety-sensitive tasks which might justify the statute's proposed incursion on their individual privacy rights. Where, as in this case, public safety was not genuinely jeopardized, the Fourth Amendment precluded a suspicionless search, no matter how conveniently arranged.

Dissent

Chief Justice Rehnquist expressed the view that the statute's urinalysis test was a reasonable search under the Fourth Amendment.