Tuesday, November 5, 2013

Ferguson v. City of Charleston case brief

Ferguson v. City of Charleston case brief summary
532 U.S. 67 (2001)

Petitioner arrestees' request for writ of certiorari to the United States Court of Appeals for the Fourth Circuit was granted in a case regarding whether a state hospital's performance of a diagnostic test to obtain evidence of a patient's criminal conduct for law enforcement purposes was an unreasonable search if the patient had not consented to the procedure.

A state hospital implemented a policy setting forth procedures to be followed by hospital staff to identify pregnant patients suspected of drug abuse. Pursuant to the policy, hospital staff members tested pregnant patients for drug abuse and reported positive tests to the police. Petitioners, women who received obstetrical care at the hospital and who were arrested after testing positive for cocaine, sued respondents, alleging that the warrantless and allegedly nonconsensual drug tests were unconstitutional searches. The federal appellate court found the searches to be reasonable as a matter of law under the "special needs" doctrine.

  • On certiorari, the court reversed the judgment. 
  • Given the primary purpose of the program, which was to use the threat of arrest and prosecution in order to force women into treatment, and given the extensive involvement of law enforcement officials at every stage of the policy, the case simply did not fit within the closely guarded category of "special needs." 
  • Therefore, U.S. Constitutional Amendment IV's general prohibition against nonconsensual, warrantless, and suspicionless searches necessarily applied to the policy.


Judgment was reversed and case was remanded for a determination of patient consent. The drug tests performed by the hospital were not excluded from the prohibition against nonconsensual, warrantless, and suspicionless searches based on "special needs."

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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