Random suspicionless drug testing of any probationer (even those from nondrug cases), satisfied the Fourth Amendment and state constitution under special needs. State v. Hinnenkamp, 2019 Kan. App. LEXIS 44 (July 5, 2019):
The State has a substantial interest in monitoring probationers to promote their rehabilitation and compliance with probation conditions. And an important part of the job is making sure that probationers abstain from using alcohol when ordered by the court and that they always abstain from the illegal use of drugs. The only way to ensure compliance with these orders is through reasonable testing. Drug and alcohol testing is most effective when the tests are administered randomly. That way, the probationer knows that he or she must completely abstain from the use of alcohol or illegal drugs because the probationer can be tested at any time for a violation.