Brief Fact Summary. A hospital developed a policy in conjunction with law enforcement officials for dealing with pregnant drug addicts.
Synopsis of Rule of Law. A policy that permits searches where the purpose served is “ultimately indistinguishable form the general interest in crime control” does not comport with the Fourth Amendment.
Issue. “[W]hether a state hospital’s performance of a diagnostic test to obtain evidence of a patient’s criminal conduct for law enforcement purposes is an unreasonable search if the patient had not consented to the procedure.”
Held. Yes. Using the “special needs” test, the court noted that “in this case . . . the central and indispensable feature of the policy from its inception was the use of law enforcement to coerce the patients into substance abuse treatment.” Further, there policy did not “discuss different courses of medical treatment for either mother or infant.” The involvement of law-enforcement officials throughout the development of the policy showed that the ultimate interest was “crime control.”
The Fourth Amendment contains no provision expressly precluding the use of evidence obtained in violation of its commands, and an examination of its origin and purposes makes clear that the use of fruits of a past unlawful search or seizure works no new Fourth Amendment wrong.View Full Point of Law