## Facts

- Georgia enacted Ga. Code Ann. § 21-2-140 requiring candidates for specified statewide offices to certify that, within 30 days before qualifying, they had taken a urinalysis drug test with a negative result.
- Covered offices included Governor, Lieutenant Governor, Secretary of State, Attorney General, and other named executive positions.
- Libertarian Party candidates subject to the requirement sued state officials responsible for enforcement, alleging constitutional violations; the Supreme Court focused on the Fourth Amendment.
- The candidates submitted to testing and filed the certificates to appear on the ballot while litigation proceeded.

## Issues

1. Whether Georgia’s mandatory, suspicionless urinalysis and certification requirement for candidates for designated state offices is a reasonable search under the Fourth Amendment.
2. Whether the requirement is justified by a “special need” beyond ordinary law enforcement sufficient to dispense with individualized suspicion.

## Decision

- The Supreme Court reversed the Eleventh Circuit.
- The Court held that the statute’s drug-testing requirement constitutes a search and falls outside the narrow category of permissible suspicionless searches.
- Georgia failed to show a concrete danger or demonstrated drug problem among candidates or officeholders that would justify departing from the ordinary requirement of individualized suspicion.
- The Court concluded that the asserted state interest was largely symbolic and that the program’s design (one-time test, candidate-selected physician, certificate reporting) further undercut any claim of necessity or tailoring.
- Chief Justice Rehnquist dissented, viewing the intrusion as modest and the state’s interest in ensuring the fitness of high-level officials as sufficient.

## Legal Principles

- Government-compelled urinalysis is a “search” under the Fourth Amendment.
- Warrantless, suspicionless searches are presumptively unreasonable and valid only in limited settings.
- Under the “special needs” doctrine, the government must show a non-law-enforcement need of sufficient immediacy and magnitude, and courts must assess reasonableness through a context-specific balancing of public and private interests.
- Symbolic interests in projecting drug-free leadership, without evidence of a concrete risk or documented problem, do not justify suspicionless drug testing of political candidates.
- A program’s limited effectiveness and weak tailoring can confirm the absence of a qualifying special need.

## Conclusion

The Court held that Georgia’s requirement that candidates for certain state offices pass and certify a drug test was an unreasonable, suspicionless search because the State did not demonstrate a concrete special need beyond normal law enforcement to justify dispensing with individualized suspicion.


Chandler v. Miller, 520 U.S. 305 (1997)