Chandler v. Miller

When the case was argued before the Supreme Court, the state of Georgia focused on drug testing programs previously upheld by the Supreme Court. These included two cases decided in 1989. The first was Skinner v. Railway Labor Executives' Assn. This case involved drug and alcohol tests performed on railway employees involved in train accidents and for those who violated particular safety rules. The second 1989 case was Treasury Employees v. Von Raab. The Treasury Employees case addressed the use of drug tests for U.S. Customs Service employees who sought transfer or promotion to certain positions. A third case cited as precedence had been decided in 1995, Vernonia School District 47J v. Acton, and concerned the use of random drug testing of students who participated in interscholastic sports.

These were the same cases cited and recognized by the Eleventh Circuit Court as the examples of reasonable searches for the purpose of identifying drug abuse. Counsel for the state of Georgia reasoned that these related cases focused on a state's interest to have programs to prevent drug abuse in special circumstances wherein lack of testing could have a serious, deleterious effect. Counsel pointed out that, as written, the Georgia statute did not have any invasive elements since nominees submitted to testing in the privacy of their own physician's office. Therefore the state could not be faulted for excessive intrusion. Finally, the respondent's attorney maintained that the existence of such a statute was warranted because use of illicit drugs in society was pervasive, and could conceivably involve even candidates who ran for state office.

The U.S. Supreme Court based its decision on four points of law. The Court agreed with petitioners that the Georgia statute's requirements were unconstitutional because respondents failed to prove and justify their reasons for authoring such a statute. Justices did not consider as valid the respondent's claim that requirements for drug testing were reasonable because there was no "individualized suspicion of wrong doing" which justified unwarranted search and seizure (a description which even the lower court applied to the drug testing requirement). Further, the Court reasoned that a state's power under the Tenth Amendment to establish criteria and procedure for state elections did not entitle a state to challenge personal rights under the Fourth Amendment.