Marchwinski v. Howard
United States Court of Appeals for the Sixth Circuit
309 F.3d 330 (2002)
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 via urine analysis 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 rights. The district court granted an injunction prohibiting Michigan from conducting drug tests on FIP applicants or recipients in the absence of individualized suspicion. Michigan appealed.
Rule of Law
Issue
Holding and Reasoning (Batchelder, J.)
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