In addition, consent to a drug test should not be a condition of promotion, although an agency can require probationary employees and job applicants to submit to a drug test. Drug testing programs should also provide for specific identification of personnel suspected of drug use and for limiting testing to the suspected persons. The identification of those persons should be based on an articulable reasonable suspicion of drug use and not on conjecture or convenience. The future potential for mandatory drug testing is uncertain, because of the small number of appellate court decisions. Most of the drug testing cases have been decided at the district court level. The case of Shoemaker v. Handel (1986) shows the reasoning applied to date. In that case, a Federal appeals court approved drug testing of horse racing jockeys by the State of New Jersey, emphasizing that horse racing is already a heavily regulated industry. Other decisions have refused to apply the Shoemaker decision to public employees, on the grounds that that area is not heavily regulated. The model policy issued by the International Association of Chiefs of Police prior to many of the court decisions suggests testing of job applicants, current employees in certain circumstances, and all employees assigned to drug enforcement units. 15 footnotes.