From the Lawrence Daily Journal-World for March 21, 1987:

Kansas Atty. Gen. Robert T. Stephan issued a legal opinion today on the issue of employee drug testing. He held that it was constitutional in Kansas to test applicants for public safety positions, but that mandatory drug testing of all public employees would violate the Fourth Amendment’s protection against unreasonable search. “However, we see no Fourth Amendment barrier to drug testing if it is in furtherance of a bona fide effort to learn whether an applicant is physically capable of performing the duties of a particular job,” Stephan said. He added that drug testing of present employees must only be done if there was a “reasonable suspicious” of a specific employee’s drug use.