Does the special needs doctrine apply when a search is conducted without a warrant?

The special needs doctrine applies if the governmental search is in furtherance of a special need beyond that of general law enforcement. Griffin v. Wisconsin, 483 U.S. 868, 873 (1987); see also City of Indianapolis v. Edmond, 531 U.S. 32, 44 (2000); Ferguson v.

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City of Charleston, 532 U.S. 67, 79 (2001). This doctrine allows the government to conduct a warrantless search when special needs make obtaining a warrant for probable cause impracticable. Griffin, 483 U.S. at 873; New Jersey v. T.L.O., 469 U.S. 325, 351 (1985).