Chandler v. Miller

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?
HOLDING: Yes.
PROCEDURAL HISTORY:
  • 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
REASONING:
  • 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 RaabVon 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
COMMENTS:
  • Suspicionless urinalysis of candidates for public office (and expectant mothers (Ferguson, infra) is not justified.

OTHER CASES:

  • 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

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