Chandler v. Miller Case Brief
United States Supreme Court
520 U.S. 305 (1997)
ISSUE: Is a state statute that requires all candidates for certain public offices to submit a certification of drug testing an unreasonable search without individualized suspicion?
- 3 Libertarian Party nominees for certain public offices brought this suit for an injunction and declaratory relief
- Dist. Ct. denied the motion for preliminary injunction
- Ct. App. affirmed
- Search: Drug testing is a search
- Govt. interest: Govt. interest is weak because there is no indication that Georgia has had a problem with public officials abusing drugs
- Scheme is not a credible means of deterring drug users from office because they choose when to undergo testing
- Ordinary law enforcement methods should be able to apprehend drug users in office
- Elected officials are constantly in the limelight and under intense scrutiny
- Need is "symbolic," not "special"
- Different than Von Raab: Von Raab dealt with customs officials working closely with vast sources of drugs, and their work is not conducive to the day-to-day scrutiny that public officials are under
- Suspicionless urinalysis of candidates for public office (and expectant mothers (Ferguson, infra) is not justified.
- Ferguson v. City of Charleston: Drug testing of pregnant women on public assistance was a necessary precondition to being able to give birth in a public hospital under public assistance. Asserted purpose was protecting the health of the mother and child.
- Unconstitutional because ultimate policy was indistinguishable from general crime control