Marchwinski v. Howard
United States District Court for the Eastern District of Michigan
113 F. Supp. 2d 1134 (2000)
Facts
In 1996, the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) replaced the Aid to Families with Dependent Children program with the Temporary Assistance for Needy Families (TANF) program, emphasizing moving recipients toward work. PRWORA authorized states to drug test TANF recipients and sanction recipients who tested positive. Michigan’s Family Independence Agency (FIA) instituted a pilot program requiring drug testing and treatment for all Family Independence Program (FIP) TANF applicants and random retesting of 20 percent of recipients after six months. Individuals who tested positive were mandated to participate in substance-abuse treatment plans. Michigan’s stated justification was to address substance abuse as a barrier to strong family relationships and employment. FIP recipients (the recipients) (plaintiffs) sued Douglas Howard (defendant), the director of FIA, contending that the program violated the recipients’ Fourth Amendment right against unreasonable search and seizure in the absence of a special need. FIA contended that a special need showing did not require implicating public safety, and even if it did, the state’s interest in identifying substance abusers who posed a danger to children met that standard.
Rule of Law
Issue
Holding and Reasoning (Roberts, J.)
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