State v. Guzman

The issue on this appeal is whether the trial court subjected Steven L. Guzman to an unconstitutional search when the court ordered Guzman to undergo a surprise drug test just prior to Guzman's scheduled sentencing. We hold that the search was reasonable under the state and federal constitutions. We therefore affirm Guzman's conviction and the order denying his application for postconviction relief.

The relevant facts are straightforward and not in dispute. On January 23,1989, the state charged Guzman as a party to the crime of unlawfully delivering a controlled substance, pursuant to secs.…