Golden Gate University Law Review


Joshua W. Rose


In Portillo v. United States District Court for the District of Arizona, the Ninth Circuit held that mandatory presentence urine testing of a convicted defendant violates the Fourth Amendment to the United States Constitution. The court concluded that, because the particular facts of the case and the lack of information about the defendant's past drug usage did not support the district court's order, urine testing was constitutionally impermissible.