In consultation with Dr. Carlton Turner, President Ronald Reagan issued Executive Order 12564. In doing so, he instituted mandatory drug-testing for all safety-sensitive executive-level and civil-service Federal employees. This was challenged in the courts by the National Treasury Employees Union. In 1988, this challenge was considered by the US Supreme Court. A similar challenge resulted in the Court extending the drug-free workplace concept to the private sector. These decisions were then incorporated into the White House Drug Control Strategy directive issued by President George H.W. Bush in 1989. All defendants serving on federal probation or federal supervised release are required to submit to at least three drug tests. Failing a drug test can be construed as possession of a controlled substance, resulting in mandatory revocation and imprisonment.