Luis W. LeBron v. Secretary, Florida Departtment of Children and Families, 2013 U.S. App. LEXIS 3998

Lebrón, TANF applicant in Florida, challenged Florida’s mandatory suspicionless drug testing statute for TANF applicants as unconstitutional under the Fourth Amendment, leading to a district court injunction.
Florida enacted May 2011 a statute, § 414.0652, requiring drug testing for TANF applicants; a negative test reimburses the test cost via TANF benefits, a positive test bars benefits for a year but allows reapplication after treatment and another test at personal expense, and the dependent child may receive TANF with a designated, tested protective payee.
Lebrón signed a consent form acknowledging testing but did not take the test; he sought to enjoin enforcement of the statute; the district court granted a preliminary injunction, and the State appeals.
The court reviews the district court’s injunction under an abuse-of-discretion standard for the injunction, with de novo review of the law and findings of fact only if clearly erroneous.
The court analyzes whether Florida’s drug-testing regime falls within the narrow “special needs” exception to the Fourth Amendment’s warrant and probable-cause requirements, concluding that the State failed to show a substantial special need justifying suspicionless testing.
Conclusion: the district court’s grant of the injunction was affirmed, and the State’s testing regime was enjoined.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the TANF drug testing constitutes a substantial special need	Lebrón argues no substantial special need exists	State asserts a substantial special need to protect TANF goals and child welfare	No substantial special need; injunction affirmed
Whether consent to testing cures unconstitutionality	Lebrón contends consent is not freely and voluntarily given	State relies on consent to render testing reasonable	Consent cannot validate an unconstitutional search; unconstitutional conditions rule applies
Whether district court properly granted preliminary injunction on the record	N/A	N/A	District court’s injunction affirmed; issue resolved on merits rather than balance of interests

Skinner v. Ry. Labor Executives’ Ass’n, 489 U.S. 602 (U.S. 1989) (upheld suspicionless testing in safety contexts; recognized searches intrude privacy but defer to special needs when substantial)
Chandler v. Miller, 520 U.S. 305 (U.S. 1997) (requires substantial special need beyond general public safety and overrides privacy interests)
Von Raab, 489 U.S. 656 (U.S. 1989) (upheld drug testing where function involves national security and drug interdiction)
Vernonia School Dist. 47J v. Acton, 515 U.S. 646 (U.S. 1995) (upheld student drug testing in public schools within special needs context)
Bd. of Educ. v. Earls, 536 U.S. 822 (U.S. 2002) (affirmed school drug testing under special needs framework)
New Jersey v. T.L.O., 469 U.S. 325 (U.S. 1985) (establishes special needs framework allowing limited intrusions in schools)
Wyman v. James, 400 U.S. 309 (U.S. 1971) (distinguishes welfare home visits from searches; not controlling for testing reasonableness)
Perry v. Sindermann, 408 U.S. 593 (U.S. 1972) (unconstitutional conditions doctrine; cannot condition benefits on surrender of constitutional rights)
Bailey v. Alabama, 219 U.S. 219 (U.S. 1911) (unconstitutional conditions principle; state cannot indirectly burden constitutional rights)
Speiser v. Randall, 357 U.S. 513 (U.S. 1958) (unconstitutional conditions doctrine applied to tax exemptions)
Ferguson v. City of Charleston, 532 U.S. 67 (U.S. 2001) (distinguished hospital-administered drug testing; not closely guarded special need)