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Luis W. Lebronv.Secretary, Florida Department Of Children And Families

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.11-15258
DecidedFebruary 26, 2013
JudgesUnited States Court of Appeals for the Eleventh Circuit
Tags
CivilCivil RightsConstitutional LawFourth AmendmentWarrantless SearchGovernment LawPreliminary InjunctionDue ProcessSpecial Concurrence
Case Summary

Luis W. Lebron, a Navy veteran and single father, qualified for Florida’s Temporary Assistance for Needy Families program but refused to undergo a mandatory drug test required by state law. He challenged the testing condition under the Fourth Amendment, and the district court entered a preliminary injunction. The Eleventh Circuit affirmed. It treated the drug test as a search and held that suspicionless searches are constitutional only in closely guarded circumstances supported by a substantial special need beyond ordinary law enforcement. Florida’s general goal of moving welfare recipients into employment did not satisfy that requirement; unlike safety-sensitive workers and public-school students, TANF applicants did not present the recognized risks or diminished privacy interests that justify suspicionless testing. The court also held that Florida could not evade the Fourth Amendment by conditioning life-sustaining benefits on a coerced waiver of the right to be free from unreasonable searches. The decision concerned only Lebron’s substantial likelihood of success at the preliminary-injunction stage, not the statute’s ultimate constitutionality. Judge Jordan concurred, stressing the limited review and the State’s burden. The injunction therefore remained in place.

Opinion

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