National Treasury Employees Union, 489 U.S. at 680-82, 109 S.Ct. 1384 (Scalia, J., dissenting). In National Treasury Employees Union, the contested search involved urine testing of Customs Service employees to protect the integrity of the agency by discharging employees who, through their own drug use, would allegedly be unable fully to perform their duty to interdict narcotics. Id. at 682, 109 S.Ct. 1384. Justice Scalia argued that the governmental purpose provided was too generalized and speculative to find the drug testing reasonable. See id. at 684, 109 S.Ct. 1384. Thus, when operating outside the warrant requirement, a “special needs” search must be narrowly tailored to achieve a legitimate purpose. See Delaware v. Prouse, 440 U.S. 648, 659, 99 S.Ct. 1391, 59 L.Ed.2d 660 (1979) (<HOLDING>). D. Focusing the Appropriate Fourth Amendment
holding evidence including that insurer only charged life insurance premium that would ordinarily apply to onehalf the amount of coverage actually permitted by policy as written did not warrant retroactive reformation of policy to reduce coverage amount because it did not demonstrate mistake on insureds part and insurance company did not present evidence on what parties agreed to before the policy was issued holding that insurers failure to deny existence of insurance coverage under policy at issue was to admit that coverage existed holding that the plaintiffs asserted legal basis for coverage is irrelevant to the determination of whether the insurance policy provides coverage and instead looking to the facts underlying the claim for coverage holding random traffic stops for license and registration checks are contrary to fourth amendment holding that random spot checks were not narrowly tailored to the purpose of ensuring an adequate amount of insurance coverage