''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

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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

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Background

Statute

In 1990,

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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 drug ...

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: physicia ...

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 A urine test is any medical test performed on a urine specimen. The analysis of urine is a valuable diagnostic tool because its composition reflects the functioning of many body systems, particularly the kidneys and urinary system, and specimens a ...

was obtained, a state-approved laboratory determined whether any of the specified illegal

drugs A drug is any chemical substance that causes a change in an organism's physiology or psychology when consumed. Drugs are typically distinguished from food and substances that provide nutritional support. Consumption of drugs can be via inhalat ...

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

Facts

In 1994, three

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candidates for such state offices statute filed an action in District Court against the

governor of Georgia The governor of Georgia is the head of government of Georgia and the commander-in-chief of the state's military forces. The governor also has a duty to enforce state laws, the power to either veto or approve bills passed by the Georgia Legisl ...

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

certiorari In law, ''certiorari'' is a court process to seek judicial review of a decision of a lower court or government agency. ''Certiorari'' comes from the name of an English prerogative writ, issued by a superior court to direct that the record of ...

, 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.

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)