have occasioned warrantless Fourth Amendment searches based upon either no individualized suspicion or suspicion less than the traditional probable cause standard in situations such as public school searches, id. at 340, 105 S.Ct. 733, public employee searches, O’Connor v. Ortega, 480 U.S. 709, 721-25,107 S.Ct. 1492, 94 L.Ed.2d 714 (1987) (plurality opinion), and, as discussed further below, searches of people on probation, Griffin v. Wisconsin, 483 U.S. 868, 876, 107 S.Ct. 3164, 97 L.Ed.2d 709 (1987). The “special needs” exception— just as in the case with the broader category of administrative searches — must serve a primary purpose separate from the general interest in crime control. See Ferguson v. City of Charleston, 532 U.S. 67, 79-80, 121 S.Ct. 1281, 149 L.Ed.2d 205 (2001) (<HOLDING>). In addition to this requirement, the “special
holding a policy that required urine testing of maternity patients invalid because its primary purpose was the use of law enforcement to coerce the patients into substance abuse treatment holding that the extensive involvement of law enforcement officials at every stage of the drug testing policy administered by the hospital did not allow the policy to fall within the special needs doctrine which has been used to uphold suspicionless searches performed for reasons unrelated to law enforcement holding that possession of a controlled substance is a crime only if the defendant knowingly possesses the substance and has knowledge of the nature of that substance holding that the economic substance of a transaction rather than its form determines its tax treatment holding to prove possession the state must show that a defendant possessed a certain substance the substance was illegal and he had knowledge of the presence of the substance