Chandler v. Miller
Annotate this Case
520 U.S. 305 (1997)
OCTOBER TERM, 1996
CHANDLER ET AL. v. MILLER, GOVERNOR OF GEORGIA, ET AL.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE ELEVENTH CIRCUIT
No. 96-126. Argued January 14, 1997-Decided April 15, 1997
A Georgia statute requires candidates for designated state offices to certify that they have taken a urinalysis drug test within 30 days prior to qualifying for nomination or election and that the test result was negative. Petitioners, Libertarian Party nominees for state offices subject to the statute's requirements, filed this action in the District Court about one month before the deadline for submission of the certificates. Naming as defendants the Governor and two officials involved in the statute's administration, petitioners asserted, inter alia, that the drug tests violated their rights under the First, Fourth, and Fourteenth Amendments to the United States Constitution. The District Court denied petitioners' motion for a preliminary injunction and later entered final judgment for respondents. Relying on this Court's precedents sustaining drug-testing programs for student athletes, Vernonia School Dist. 4- 7 J v. Acton, 515 U. S. 646, 650, 665-666, Customs Service employees, Treasury Employees v. Von Raab, 489 U. S. 656, 659, and railway employees, Skinner v. Railway Labor Executives' Assn., 489 U. S. 602, 608-613, the Eleventh Circuit affirmed. The court accepted as settled law that the tests were searches, but reasoned that, as was true of the drug-testing programs at issue in Skinner and Von Raab, the statute served "special needs," interests other than the ordinary needs of law enforcement. Balancing the individual's privacy expectations against the State's interest in the drug-testing program, the court held the statute, as applied to petitioners, not inconsistent with the Fourth and Fourteenth Amendments.
Held: 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. Pp. 313-323.
(a) It is uncontested that Georgia's drug-testing requirement, imposed by law and enforced by state officials, effects a search within the meaning of the Fourth and Fourteenth Amendments. The pivotal question here is whether the searches are reasonable. To be reasonable under the Fourth Amendment, a search ordinarily must be based on individualized suspicion of wrongdoing. See Vernonia, 515 U. S., at 652-653. But particularized exceptions to the main rule are sometimes
warranted based on "special needs, beyond the normal need for law enforcement." See Skinner, 489 U. S., at 619. When such "special needs" are alleged, courts must undertake a context-specific inquiry, examining closely the competing private and public interests advanced by the parties. See Von Raab, 489 U. S., at 665-666. In evaluating Georgia's ballot-access, drug-testing statute-a measure plainly not tied to individualized suspicion-the Eleventh Circuit sought to balance the competing interests in line with this Court's precedents most immediately in point: Skinner, Von Raab, and Vernonia. Pp. 313-317.
(b) These precedents remain the guides for assessing the validity of the Georgia statute despite respondents' invitation to apply a framework extraordinarily deferential to state measures setting conditions of candidacy for state office. No precedent suggests that a State's sovereign power to establish qualifications for state offices diminishes the constraints on state action imposed by the Fourth Amendment. pp. 317-318.
(c) Georgia's testing method is relatively noninvasive; therefore, if the "special need" showing had been made, the State could not be faulted for excessive intrusion. However, Georgia has failed to show a special need that is substantial-important enough to override the individual's acknowledged privacy interest, sufficiently vital to suppress the Fourth Amendment's normal requirement of individualized suspicion. Respondents contend that unlawful drug use is incompatible with holding high state office because such drug use draws into question an official's judgment and integrity; jeopardizes the discharge of public functions, including antidrug law enforcement efforts; and undermines public confidence and trust in elected officials. Notably lacking in respondents' presentation is any indication of a concrete danger demanding departure from the Fourth Amendment's main rule. The statute was not enacted, as respondents concede, in response to any fear or suspicion of drug use by state officials. A demonstrated problem of drug abuse, while not in all cases necessary to the validity of a testing regime, see Von Raab, 489 U. S., at 673-675, would shore up an assertion of special need for a suspicionless general search program, see Skinner, 489 U. S., at 606-608; Vernonia, 515 U. S., at 662-663. In contrast to the effective testing regimes upheld in Skinner, Von Raab, and Vernonia, Georgia's certification requirement is not well designed to identify candidates who violate antidrug laws and is not a credible means to deter illicit drug users from seeking state office. The test date is selected by the candidate, and thus all but the prohibitively addicted could abstain for a pretest period sufficient to avoid detection. Respondents' reliance on this Court's decision in Von Raab, which sustained a drug-
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