1. 152. 489 U.S. 602 (1989).
2. 150. Two aspects of Griffin indicated that a majority of the Court in 1987 would apply the special needs exception with consider leeway in favor of the state. First, although the Court ruled that the search of Griffin's home was reasonable because, inter alia, it was done pursuant to an administrative regulation that required “reasonable grounds” for a search, the facts in Griffin provided, at best, a “feeble justification” for a search. Griffin, 483 U.S. at 887–90 ( Blackmun, J. , dissenting) (explaining that the facts did not justify a search even under a reasonable suspicion standard). Second, the clear presence of a law enforcement motive for the challenged search did not negate the applicability of the special needs exception. As Justice Scalia would subsequently acknowledge years later, “the special-needs doctrine was developed, and is ordinarily employed, precisely to enable searches by law enforcement officials who, of course, ordinarily have a law enforcement objective” for their searches. Ferguson 532 U.S. at 100 ( Scalia, J. , dissenting). A majority of the current Court, however, has not embraced Justice Scalia's position. See infra notes 186–204 and accompanying text.
3. 255. Kaye, “DNA Sampling on Arrest,” supra note 83, at 487 (footnote omitted).
4. 220. Id.
5. 78. La. R.S. 15:602 (2004).