The National Federation of Federal Employees challenged the constitutionality of a random drug testing policy applicable to all employees working at Job Corps Civilian Conservation Centers operated by the U.S. Forest Service. The District Court granted summary judgment in favor of the Secretary of Agriculture and the Chief of the U.S. Forest Service and denied the Union’s request for a preliminary injunction. Upon review, the United States Court of Appeals for the District of Columbia concluded that the Secretary failed to demonstrate “special needs” rendering the Fourth Amendment requirement of individualized suspicion unreasonable.
The Fourth Amendment prohibits the government from violating “[t]he right of the people to be secure in their persons . . . against unreasonable searches and seizures.” Among the “few specifically established and well-delineated exceptions to that general rule,” is an exemption for conditions in which “special needs, beyond the normal need for law enforcement, make the warrant and probable-cause requirement impracticable.”
In demonstrating that the governmental interests were “important enough to justify the particular search at hand, in light of other factors that show the search to be relatively intrusive upon a genuine expectation of privacy,” the Secretary had to deliver a foundation for his determination that the condition of individualized suspicion was unreasonable in the Forest Service Job Corps context.
The United States Court of Appeals stated that the Secretary offered no foundation for concluding there is a serious drug problem among staff that threatened these interests and rendered the requirement for individualized suspicion impractical.
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