Ferguson v. City of Charleston Case Brief

Why is the case important?

A hospital developed a policy in conjunction with law enforcement officials for dealing with pregnant drug addicts.

Facts of the case

After an increase in the use of cocaine by patients receiving prenatal care, the Medical University of South Carolina (MUSC) started to cooperate with Charleston to formulate a policy to prosecute mothers whose children tested positive for drugs at birth. MUSC obstetrical patients were arrested after testing positive for cocaine. They filed suit challenging the policy’s validity on the theory that warrantless and nonconsensual drug tests conducted for criminal investigatory purposes were unconstitutional searches. Among the District Court’s actions was an instruction to the jury to find for the patients unless they had consented to such searches. The jury found in favor of the city. In affirming, the Court of Appeals held that the searches were reasonable, reasoning that special needs may, in certain exceptional circumstances, justify a search policy designed to serve non-law-enforcement ends.

Question

Whether a state hospital’s performance of a diagnostic test to obtain evidence of a patient’s criminal conduct for law enforcement purposes is an unreasonable search if the patient had not consented to the procedure.

Answer

Yes. Using the special needs test, the court noted that in this case . . . the central and indispensable feature of the policy from its inception was the use of law enforcement to coerce the patients into substance abuse treatment. Further, there policy did not discuss different courses of medical treatment for either mother or infant. The involvement of law-enforcement officials throughout the development of the policy showed that the ultimate interest was crime control.

Conclusion

No.

  • Case Brief: 2001
  • Petitioner: Ferguson
  • Respondent: City of Charleston
  • Decided by: Rehnquist Court

Citation: 532 US 67 (2001)
Argued: Oct 4, 2000
Decided: Mar 21, 2001