Chandler v. Miller

Justices specifically felt there were no "special needs" that permitted violation of Fourth Amendment rights which protect society against unreasonable searches; neither was there a proven, compelling necessity to require drug tests for nominees to the ballot. Writing for the majority, Justice Ginsburg observed that personal rights "diminished for a symbol's sake" did not constitute a valid reason to infringe on personal rights of nominees. Justices found the respondent's arguments as spurious that there existed a potential for drug abuse among politicians. Instead, the majority opinion went on to reason, the state's fears seemed more hypothetical than real. Nominees for state office were exposed to the public, their conduct attracted the attention of society and they were thus likely to find such exposure sufficient reason to refrain from drug use. Moreover, the Court felt that "state officials typically do not perform high-risk, safety sensitive tasks, and required certification immediately aids no interdiction effort." Furthermore the Court reasoned that Georgia's certification requirement did not succeed in its effort to identify drug abusers because tests were given with advance notice. Unlike Skinner, Treasury Employees, and Vernonia School District, where tests were scheduled without precise timing, users of illegal drugs could thus abstain for a period prior to testing long enough not to be detected. The Supreme Court thus felt that the Georgia statute was not only unconstitutional, but procedurally flawed.

During oral arguments brought before the Court, justices questioned the respondent's attorney as to whether there were real indications that Georgia has special problems with drug abuse among state officeholders. Counsel for the respondent said, "No, there is no such evidence . . . and to be frank, there is no such problem as we sit here today." Accordingly, the justices held that there was no argument showing real need for establishing a suspicionless program of drug testing among nominees for state office. Thus, cases and rationale on which the respondent based its defense were rendered impertinent to the facts of the case. In her final statement, Justice Ginsburg summarized the Court's characterization of Georgia's attempt to require drug testing for nominees running for state office. The justices almost unanimously agreed. Only Justice Rehnquist dissented. The majority of justices held that the existence of the Georgia statute was "symbolic." They asserted that there existed no discernible "special" need that served the state's argument. Additionally, the Court concluded with this commentary: "We reiterate, too, that where the risk to public safety is substantial and real, blanket suspicionless searches calibrated to the risk may rank as `reasonable.' But where, as in this case, public safety is not genuinely in jeopardy, the Fourth Amendment precludes the suspicionless search, no matter how conveniently arranged."

The only justice who dissented, Chief Justice Rehnquist, thought that the majority opinion, "had been distorted with novelty of the case." Agreeing that the state of Georgia had reason to fear political leaders may succumb to drug abuse, Rehnquist pointed out that drug abuse is one of the most dangerous problems that exists in the United States, and therefore the state was presented with a potential dilemma that could not be ignored. It was not unreasonable to assume that usage of drugs might be extended even to candidates for public office. Rehnquist therefore considered the Georgia statute a correct exercise of a state's legal right, under the Tenth Amendment of the Constitution, to create such a "prophylactic mechanism."