Chandler v. Miller
520 U.S. 305, 117 S.Ct. 1295, 137 L.Ed.2d 513 (1997)
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Rule of Law:
A state law requiring candidates for designated public offices to pass a drug test violates the Fourth Amendment because a generalized governmental interest in projecting an anti-drug image does not constitute a "special need" sufficient to justify a suspicionless search.
Facts:
- In 1990, Georgia enacted a statute requiring candidates for certain high-level state offices to certify they had tested negative for illegal drugs.
- The law required candidates to submit a certificate from a state-approved laboratory reporting a negative result on a urinalysis test taken within 30 days prior to qualifying for the ballot.
- The designated offices included Governor, Lieutenant Governor, judges, and members of the General Assembly.
- Walker L. Chandler, Sharon T. Harris, and James D. Walker were Libertarian Party nominees in 1994 for state offices subject to the drug testing requirement.
- The state of Georgia acknowledged that the statute was not enacted in response to any evidence or suspicion of drug use by state officials.
Procedural Posture:
- Walker Chandler and other Libertarian Party nominees sued Governor Zell Miller in the U.S. District Court for the Northern District of Georgia, seeking to enjoin the enforcement of the drug testing statute.
- The District Court denied the petitioners' motion for a preliminary injunction.
- After the petitioners submitted to the tests and appeared on the ballot, the District Court entered a final judgment for the state officials (respondents).
- The petitioners appealed to the U.S. Court of Appeals for the Eleventh Circuit.
- A divided panel of the Eleventh Circuit affirmed the trial court's judgment, holding the statute was constitutional.
- The petitioners successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does Georgia's statute requiring candidates for designated state offices to pass a drug test to qualify for the ballot violate the Fourth Amendment's prohibition against unreasonable searches and seizures?
Opinions:
Majority - Justice Ginsburg
Yes. Georgia's requirement that candidates for state office pass a drug test does not fit within the closely guarded category of constitutionally permissible suspicionless searches. The Court reasoned that while a state-mandated drug test is a search under the Fourth Amendment, it can only be justified without individualized suspicion if it serves a "special need" beyond normal law enforcement. Unlike prior cases involving railway employees (Skinner), customs agents (Von Raab), or student-athletes (Vernonia), Georgia failed to demonstrate any substantial or concrete danger that the drug testing program addressed. The state admitted there was no history of drug abuse among its officials. Therefore, the law's purpose was merely symbolic—to project an anti-drug image—which is not a "special need" sufficient to override an individual's privacy interests protected by the Fourth Amendment.
Dissenting - Chief Justice Rehnquist
No. The Georgia statute requires a reasonable search that is consistent with the Fourth Amendment. The majority distorts precedent by requiring a demonstrated problem before the state can act. As established in Von Raab, the government need not wait for a crisis to implement prophylactic measures to ensure the integrity of its officials. The state has a compelling interest in preventing illegal drug users from holding high office due to risks of bribery, blackmail, and impaired judgment. The privacy intrusion is minimal, as candidates can take the test at their own doctor's office, and candidates for public office already have a diminished expectation of privacy due to intense public scrutiny.
Analysis:
This decision significantly clarifies and narrows the scope of the "special needs" doctrine, which permits suspicionless searches in limited contexts. The Court established that a purely symbolic or image-based governmental interest, without evidence of a real and concrete danger, is insufficient to override the Fourth Amendment's default requirement of individualized suspicion. This precedent protects political candidates from intrusive searches justified solely on the government's desire to "set a good example," distinguishing their roles from the high-risk, safety-sensitive positions where such testing had been previously upheld. The ruling reinforces that the special needs exception is a narrow one, reserved for situations where public safety or other vital interests are genuinely at stake.
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