Skinner v. Railway Labor Executives’ Association 489 U.S. 602 (1989).
Skinner is the Petitioner and Railway Labor Executives’ Association is respondents in the U.S. Supreme Court. Case No 489 U.S. 602 (1989) before the Judges Kennedy, RHENQUIST, C.J, White, Blackmun, O’Connor, Scalia, Stevens and Brenman
Whether the Regulations requiring employees of private railroads to undergo tests for presence of alcohol or drug violated the Fourth Amendment of the Constitution.
Facts
Federal Railroad Administration (FRA)’s Regulations require blood and urine tests to be conducted on the covered employees who had been on duty on trains involved in accidents or at the time of occurrence of certain incidents. Federal District Court where the present respondents brought suit to enjoin the regulations, found for the Petitioners (herein respondents) concluding that the Regulations did not violate the Fourth Amendment. The Court of Appeals reversed the lower court’s judgment holding that a suspicion is essential to decide if a toxicological testing is necessary and reasonable under the Fourth Amendment for the reason that such a requirement would ensure that the tests which would show the presence of drug metabolites even for weeks following ingestion are however confined to detection of current impairment.
Legal Issue
Whether the Fourth Amendment can be applied to the testing of drug and alcohol authorized by the FRA Regulations.
Court’s Analysis/Decision
The U.S. Supreme Court held that the mandated tests for the presence of drugs cannot be a private action beyond the scope of Fourth Amendment. A railroad although a private agent acts under the regulations mandated by the sovereign authority and should therefore be construed as an agent of the Government. For the contention that the analysis of the biological samples amounts to searches of the person subject to Fourth Amendment, the court agrees that it is a compelled intrusion into the body for blood to be conducted for the presence of alcohol and therefore constitute searches. Compelling a person for breath test also amounts to search touching upon bodily integrity. The drug and alcohol tests conducted under the FRA regulations should be considered reasonable under the Fourth Amendment and the absence of a requirement of a warrant or on a reasonable suspicion and compelling governmental interests outweigh the privacy concerns. The Governmental intervention by regulating that railroad employees engaged in safety related tasks must be subjected to blood and urine analysis is justified in the interest of safety of the travelling public and the employees themselves. This clearly shows that employees are prohibited from consuming alcohol or drug while on duty and also while in readiness or subject to being called for duty. This requirement justifies relaxation of warrant and reasonable cause conditions. If warrant is insisted, the effect of drug or alcohol on the body or its presence in the body can never detected by the time warrant arrives hours or days after an accident or an incident. This would result in destruction of evidence of valuable evidence as alcohol and drugs are eliminated from blood stream at a constant rate. The judgment held that appeal court’s decision that the regulations are unreasonable and that tests in question cannot detect current impairment is seriously flawed since the presence of even limited amounts would provide for basis for further investigation.
- The employees to be tested work for safety of the public irrespective of they being employees of the Federal Government or Private business. The testing procedures were subject to the Fourth Amendment requirement because it involved intrusion of privacy of the employees concerned.
- The employees whether public or private can be protected under Fourth Amendment requirements if the jobs in which are placed in are not as sensitive as that of railroad employees entrusted with public safety. Hence, when it comes to public safety and possibility of destruction of evidence, warrant requirements would defeat the very purpose of requirements such as bold and urine testing.
- The interests of individuals’ Fourth Amendment’s rights are balanced against the governmental interests which must ensure public safety. As Judge Kennedy observed, the decision of the U.S. Supreme Court is justified because such a requirement will discourage employees from consuming drug or alcohol for the fear that they would be exposed and removed from jobs and even punished for criminal negligence.
Works Cited
Skinner v. Railway Labor Executives’ Association 489 U.S. 602 (1989).
