Chandler v. Miller

PETITIONER:Walker L. Chandler
LOCATION:Camp Newfound Owatonna

DOCKET NO.: 96-126
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Eleventh Circuit

CITATION: 520 US 305 (1997)
ARGUED: Jan 14, 1997
DECIDED: Apr 15, 1997

Patricia Guilday – Argued the cause for the respondents
Walker L. Chandler – Argued the cause pro se for the petitioners

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.


Did Georgia’s drug testing statute violate the Fourth Amendment’s guarantee against illegal search and seizures?

Media for Chandler v. Miller

Audio Transcription for Oral Argument – January 14, 1997 in Chandler v. Miller

Audio Transcription for Opinion Announcement – April 15, 1997 in Chandler v. Miller

William H. Rehnquist:

…against Miller will be announced by Justice Ginsburg.

Ruth Bader Ginsburg:

We review and reverse in this case, a judgment of the United States Court of Appeals for the Eleventh Circuit.

In 1990, Georgia enacted a law requiring candidates for certain state offices to certify that they have taken a urinalysis drug test and that the test result was negative.

Petitioners are Libertarian Party nominees for Lieutenant Governor and other elected officers.

Proceeding in federal court, they challenged Georgia’s ballot access drug testing law as incompatible with the Fourth Amendment but the Fourth Amendment’s protection against unreasonable searches.

The district court and then the Court of Appeals upheld the drug testing scheme.

It is uncontested that the urine collection and test Georgia requires counts as asserts within the meaning of the Fourth Amendment because it intrudes untraditional expectations of privacy.

The pivotal question we confront is whether the search is reasonable.

To be reasonable, a search ordinarily must stem from individualized suspicion of wrongdoing.

Exceptions to the main rule of suspicion focused on particular individual maybe warranted however, when the state has special needs beyond the normal need for law enforcement.

We have upheld as justified by such special needs, drug testing programs for student athletes, custom service offices transferred to dangerous or sensitive post, and railway employees involved in accidents and safety violations.

Relying on these precedents, the Eleventh Circuit concluded that the Georgia statute satisfied the Fourth Amendment’s reasonableness requirement.

In an opinion distinguishing our prior decisions, we reverse the judgment of the Court of Appeals.

Georgia’s requirement that candidate for state office pass a urinalysis drug test does not fit within the closely guarded category of constitutionally permissible suspicion list searches.

The statute, all agree, was not enacted in response to any fear or suspicion of illegal drug use by Georgia state officials.

Counsel for respondents acknowledged the absence of any such problem in the state and the certification requirement is not well designed to identify candidates who violate anti-drug laws.

The test date is picked by the candidate, so all but the uncontrollably addicted for the state protection.

Respondents rely heavily on our decision in Treasury Employees v. Von Raab in which we sustained a drug testing program for custom service employees transferred to certain high risk positions.

We did so despite the absence of documented evidence of a drug abuse problem among custom service employees but Von Raab arose in a unique setting, drug interdiction had become the agency’s primary enforcement mission and the covered posts directly involved drug interdiction or require the employee to carry a firearm.

The solitary nature of the customs service employees’ work limited to service could not these of the subject the offices in question to the day-to-day scrutiny that is a norm in more traditional work environment.

In contrast, the day-to-day conduct of candidates for public office attract attention notably beyond the norm in ordinary work environments.

What is left after close review of Georgia scheme, is the state interest, not in public safety but in projecting an image, Georgia seeks to display to the public its firm commitment to the struggle against drug abuse.

The need projected, unlike the need demonstrated in prior decisions is symbolic, not actual and special.

However well meant, the candidate drug test that Georgia has devised diminishes personal privacy for a symbol’s sake.

The Fourth Amendment shields society against state action of that kind.

The Chief Justice has filed a dissenting opinion.