The American Federation of State, County and Municipal Employees challenged a Florida executive order requiring suspicionless drug testing of roughly 85,000 state employees. The union argued that the order violated the Fourth Amendment because it covered employees without distinguishing safety-sensitive positions from ordinary jobs. The district court granted the union summary judgment and enjoined testing under the order. The Eleventh Circuit held that suspicionless testing can be reasonable when the government proves a sufficiently strong special need, but that analysis must account for the specific job category and its employees’ privacy expectations. Florida relied on generalized interests in workplace safety, productivity, and efficiency and did not show why every covered position presented a comparable risk. The court also held that the district court’s injunction was too broad because it prohibited applications that might be constitutional, including testing of genuinely safety-sensitive employees. The union’s showing shifted the burden of production to the State, but the union retained the ultimate burden of persuasion. The court vacated both the declaratory judgment and injunction and remanded for category-by-category analysis and a properly tailored remedy.