Chandler v. Miller Case Brief

Why is the case important?

Libertarian Party nominees challenged a Georgia statute requiring proof of urinalysis drug test to qualify for nomination to election.

Facts of the case

Under a Georgia statute, all candidates for elected state office must pass a urinalysis drug test within 30 days prior to their qualifying for nomination or election. Chandler, on behalf of several state office nominees from the Libertarian Party, challenged the statute’s constitutionality, naming Georgia’s governor and two other regulatory officials as defendants. On appeal from an adverse District Court ruling, the Eleventh Circuit affirmed and the Supreme Court granted certiorari.

Question

Whether a Georgia requirement that candidates take a drug test ranks among the limited circumstances in which suspicionless searches are warranted.

Answer

No. The court acknowledged that Georgia has effectively limited the invasiveness of the testing procedure, and concentrated on the question as to whether the testing was a special need. While the State argued that the use of illegal drugs draws into question an official’s judgments and integrity, etc., the court dismissed that logic noting nothing in the record hints that the hazards respondents broadly describe are real and not simply hypothetical for Georgia’s polity. Moreover, the Georgia law is not well designed to identify candidates who violate anti-drug laws nor is it a credible means to deter illicit drug users from seeking election to state office. The State offered no reason why ordinary law enforcement methods would not suffice to apprehend addicts attempting to enter politics. In conclusion, the court held, the need revealed . . . is symbolic, not ‘special’.

Conclusion

“The Court held that Georgia’s requirement that candidates for state office pass a drug test was outside the category of constitutionally permissible suspicionless searches. The Court emphasized that the proffered special need for drug testing must be substantial–important enough to override the individual’s acknowledged privacy interest, sufficiently vital to suppress the Fourth Amendment’s normal requirement of individualized suspicion. The Court found that Georgia failed to show, in justification of Ga. Code Ann. § 21-2-140 , a special need of that kind. Notably lacking in respondent officials’ presentation was any indication of a concrete danger that demanded departure from the Fourth Amendment’s main rule. The statute was not needed and could not work to ferret out lawbreakers, and officials barely attempted to support the statute on that ground. However well meant, the candidate drug test Georgia devised diminished personal privacy for a symbol’s sake

  • state action that is prohibited by the Fourth Amendment . Where, as in this case, public safety was not genuinely jeopardized, the Fourth Amendment precluded a suspicionless search, no matter how conveniently arranged.”
    • Case Brief: 1997
    • Petitioner: Walker L. Chandler
    • Respondent: Zell D. Miller
    • Decided by: Rehnquist Court

    Citation: 520 US 305 (1997)
    Argued: Jan 14, 1997
    Decided: Apr 15, 1997