Chandler v. Miller
Citation and Court
520 U.S. 305 (1997) — Supreme Court of the United States
Facts
Georgia required candidates for certain state offices to certify that they had tested negative for illegal drugs within 30 days before qualifying to run. Libertarian Party candidates challenged the requirement as an unconstitutional search under the Fourth Amendment, arguing Georgia could not demonstrate a genuine special needs justification.
Issue
Does a state law requiring candidates for designated state offices to pass a drug test violate the Fourth Amendment?
Holding
Yes; Georgia’s drug-testing requirement for political candidates is an unconstitutional search because the State has failed to demonstrate a special need sufficient to override the Fourth Amendment’s normal warrant and individualized suspicion requirements.
Rule / Doctrine
Suspicionless drug testing is permissible as a “special needs” exception to the Fourth Amendment only when a genuine special need exists beyond normal law enforcement, the privacy intrusion is minimal, and the government’s interest is substantial. Symbolic or political interests alone are insufficient; there must be an actual, demonstrated safety or other compelling need.
Significance
Chandler is an important limit on the special-needs doctrine, making clear that not every government drug-testing program qualifies. It requires a real showing of a genuine need (as in Skinner v. Railway Labor Executives and National Treasury Employees Union v. Von Raab involving safety-sensitive positions) rather than a mere desire to project an image of drug-free government.