Fourth Amendment, search, cocaine, special needs, reasonable suspicion, drug test

The Supreme Court of Wisconsin rules on whether a surprise drug test, ordered without warrant or probable cause, violates the Fourth Amendment of the Constitution or Article I of the Wisconsin Constitution. Steven Guzman had been convicted of delivering a controlled substance, and at the sentencing hearing was ordered to submit to a surprise urinalysis test without probable cause or search warrant.

The Wisconsin Court of Appeals ruled against Guzman, affirming a circuit court ruling which held that the search and urinalysis test was constitutional.

Guzman loses. The Supreme Court of Wisconsin affirmed the ruling of the court of appeals. The court noted that the "special needs" clause outweighs the requirement of a warrant or probable cause in certain instances-specifically, when the sentencing court needs information "relevant to whether probation is an appropriate, safe, useful and reasonable disposition of the criminal."