Case Brief - Lebron V. Florida

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Lebron v. Florida, 820 F.Supp.2d 1273 (M.D. Fla. 2011)

FACTS

In July 2011, Luis W. Lebron, who was an honorably discharged navy officer, applied for Florida’s Temporary Assistance for Needy Families program (“TANF”) for himself and his young son. One of the qualifications for acceptance into the program was the signed release and consent to drug testing and the conditional approval for assistant upon a negative return of a drug test in the form of urine analysis. Lebron signed the form, giving consent to test, but filed suit before ever taking the actual drug test.

HISTORY

Lebron, individually and one behalf of other TANF applicants, filed a class action lawsuit against the states of Florida, claiming that Fla Stat. § 414.0652 (“HB 353”) was a violation of his Fourth Amendment Right to the U.S. Constitution. He claimed that he was protected from suspicionless drug testing in order to receive government assistance by unreasonable search granted by the Fourth Amendment. Additionally, Lebron filed a preliminary injunction on the mandatory drug test until the case could be heard and rule upon. After the courts granted the injunction the state halted its testing program.

ISSUE

Under Fla Stat. § 414.0652, does “unreasonable searches” include suspicionless drug testing in order to receive government aid?

DECISION

Yes, “unreasonable searches” is extended to cover suspicionless drug testing for applicant for government aid.

RATIONALE

The courts reasoned that the states claim of “special needs” was not founded as it did not show cause that suspicionless drug testing posed a immediate threat to public safety nor were applicants the “first line of defense”. Additionally, applicants did not meet the “Closely guarded category” of government funded schools. Therefore, the administering of suspicionless drug testing would do more harm in that good to protect the publics’ safety.

NOTES: Is it unrealistic to assume that if someone wants money they should...