''Chandler v. Miller'', 520 U.S. 305 (1997), was a case before the
United States Supreme Court
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
concerning the Constitutionality under the
Fourth Amendment of a state statute requiring drug tests of all candidates for certain
state
State may refer to:
Arts, entertainment, and media Literature
* ''State Magazine'', a monthly magazine published by the U.S. Department of State
* ''The State'' (newspaper), a daily newspaper in Columbia, South Carolina, United States
* ''Our S ...
offices. The case is notable as being the only one in recent years where the Supreme Court has upheld a challenge to a
ballot access
Elections in the United States refers to the rules and procedures regulating the conditions under which a candidate, political party, or ballot measure is entitled to appear on voters' ballots. As the nation's election process is decentralized b ...
restriction from members of a third party, in this case the
Libertarian Party of Georgia
Founded in 1971, The Libertarian Party of Georgia is a state affiliate of the United States Libertarian Party.
Executive committee
The executive committe in 2017 consisted of four members.
Candidates
Notable candidates include John Monds's ru ...
.
Background
Statute
In 1990,
Georgia
Georgia most commonly refers to:
* Georgia (country), a country in the Caucasus region of Eurasia
* Georgia (U.S. state), a state in the Southeast United States
Georgia may also refer to:
Places
Historical states and entities
* Related to the ...
enacted a statute which required candidates for designated state office to certify that they had taken a
drug test
A drug test is a technical analysis of a biological specimen, for example urine, hair, blood, breath, sweat, or oral fluid/saliva—to determine the presence or absence of specified parent drugs or their metabolites. Major applications of dr ...
and obtained negative results. The candidate could provide test specimen at a
laboratory
A laboratory (; ; colloquially lab) is a facility that provides controlled conditions in which scientific or technological research, experiments, and measurement may be performed. Laboratory services are provided in a variety of settings: physic ...
approved by the state or at the office of the candidate's personal
physician
A physician (American English), medical practitioner (Commonwealth English), medical doctor, or simply doctor, is a health professional who practices medicine, which is concerned with promoting, maintaining or restoring health through th ...
. 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.
Facts
In 1994, three
Libertarian Party
Active parties by country
Defunct parties by country
Organizations associated with Libertarian parties
See also
* Liberal parties by country
* List of libertarian organizations
* Lists of political parties
Lists of political part ...
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. 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.
Additionally, 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.
See also
*
List of United States Supreme Court cases, volume 520
This is a list of all the United States Supreme Court cases from volume 520 of the ''United States Reports
The ''United States Reports'' () are the official record ( law reports) of the Supreme Court of the United States. They include rulings, ...
*
List of United States Supreme Court cases
This page serves as an index of lists of United States Supreme Court cases. The United States Supreme Court is the highest federal court of the United States.
By Chief Justice
Court historians and other legal scholars consider each Chief J ...
*
Lists of United States Supreme Court cases by volume
The following is a complete list of cases decided by the United States Supreme Court organized by volume of the ''United States Reports'' in which they appear. This is a list of volumes of ''U.S. Reports'', and the links point to the contents of e ...
References
External links
*
{{US4thAmendment, warrantexceptions, state=expanded
United States Supreme Court cases
United States controlled substances case law
United States Fourth Amendment case law
1997 in United States case law
United States Supreme Court cases of the Rehnquist Court
Drug testing
Libertarian Party (United States)
United States elections case law
Legal history of Georgia (U.S. state)