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Chandler v. Miller


A state law required candidates for specific state offices to certify that they had taken a drug test and the results were negative. The test date is scheduled by the candidate anytime within 30 days prior to ballot qualification.


Whether the government’s process is designed to pursue the “special needs” set out in the statute?


No. The process the government attempted to implement is too inefficient to constitute an effective test.


The Court held that “[W]hen 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.” Where the public interests are substantial (as in Skinner, Vernonia and Von Raab), such warrantless, suspicionless searches are reasonable. However, each of these cases was warranted by a “special need.” In the case at hand, the Court noted that “Georgia’s certification requirement is not well designed to identify candidates who violate antidrug laws.” Candidates subject to the statute have notice of when the drug test is taking place. In fact, the candidates themselves schedule the drug tests. The government’s claim that these warrantless, suspicionless, special needs searches deters drug users from gaining high office within the state was not very persuasive. Likewise, the Court held that the state could produce no evidence that it currently had drug problems among its elected officials or that their officials perform risky, safety sensitive tasks.


520 U.S. 305, 117 S. Ct. 305 (1997)

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