Mandatory Drug Testing

Mandatory Drug TestingAuthor(s): ANDREA NEALSource: ABA Journal, Vol. 74, No. 10 (OCTOBER 1, 1988), pp. 58-63Published by: American Bar AssociationStable URL: http://www.jstor.org/stable/20760154 .Accessed: 12/06/2014 15:39

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IN THE SUPREME COURT

Mandatory Drug Testing

BY ANDREA NEAL

Tom Mullowney still bristles at the memory of that October day when he entered the Upjohn of

fice for a drug test the final step be fore he could be promoted to senior inspector for the Customs Service in New York.

"1 was directed to a woman who I assumed was a nurse," Mullowney recalls. "She handed me the sample bottle and accompanied me into the men's room. Naturally, it was kind of embarrassing."

Mullowney, 38, closed the stall door, collected his urine specimen, handed it to the woman and quickly departed. A few days later, his test came back negative and the job was his.

The scene is one repeated count less times a day as the government and private sector increasingly turn to mandatory urine testing in their effort to create a drug-free work place.

A June 1988 Gallup Poll shows that 28 percent of the nation's largest companies, including General Motors and AT&T, screen their workers for drug use. President Reagan has or dered all federal agencies to develop plans for testing employees in so called sensitive positions, ranging from secretaries to CIA agents.

And Congress has threatened to withdraw funds from local govern ments that fail to give drug tests to transit workers.

But the trend toward mandatory drug testing is not without critics. For many, like customs agent Tom Mul lowney, there is something about drug testing that offends traditional notions of personal privacy. Does the war on drugs justify an employer's intrusion into one's personal affairs?

Like so many of the controver sial issues of our day, it is a question that only the Supreme Court can an

Andrea Neal is a Supreme Court reporter for UPI in Washing ton, D.C.

swer. With federal and state courts split on the issue, the justices this fall will hear arguments to determine if drug testing by the government is permissible and, if so, under what conditions. Legal experts, noting that drug testing is a fairly recent phe nomenon, say the high court has stepped in quickly to referee the con stitutional battles being waged in lower courts.

"This appears to be a situation where at least four justices felt there wasn't much choice but to resolve the situation," says Lawrence Baum, a

political science professor at Ohio University and author of a, book on the Court. 'Things were going to be fairly chaotic if they didn't begin to tackle the issue."

The Court's inquiry will focus on two cases, National Treasury Em ployees Union v. Von Raab, No. 86 1879, and Burnley v. Railway Labor

Executives'Association, No. 87-1555.

The first case involves a pro gram at the Customs Service to test

applicants for jobs in certain posi tions, such as those involved in the interdiction of illegal drugs. That

program, justified by the Customs Service as a way to ensure the integ rity of its law enforcement efforts, has been upheld by the 5th Circuit.

The second case challenges the federal government's requirement that blood and urine tests to detect alcohol and drugs be conducted on all crew members of trains involved in accidents. Although defended on

public safety grounds, the program was struck down by the 9th Circuit.

By taking both cases, the Court can examine drug testing in two very different contexts.

One is a government agency that believes a drug-free workforce is es sential to its mission of stopping drugs from flowing across the border, the other is the heavily regulated trans portation industry in which the lives of the public are at stake. Neither in volves random testing.

'These are cases that probably have circumstances relatively favor able Tor testing," Baum observes. 'They involve situations in which the case for testing is stronger than in other contexts. If the Court rules in favor of them, it will still leave the question of how far the Court is going to go. If the Court goes the other di rection and says the programs are not acceptable, that might really be a blow to all testing programs."

The Customs Service was among the first federal agencies to put its testing program into effect in

June 1986 following a six-month study by a special drug-screening task force. The task force found that "cus toms is largely drug-free," but none theless concluded that a testing program would help ensure that cus toms officers are able to think and react quickly on the job and are not susceptible to bribery by the very drug smugglers they are supposed to combat.

Under the program, all new ap plicants and current employees seek ing promotions must pass a urine test to qualify for positions involving drug interdiction, the carrying of firearms or access to classified material. The

Court

Weighs

Civil

Liberties

Objections

58 ABA JOURNAL / OCTOBER 1, 1988


http://www.jstor.org/page/info/about/policies/terms.jsp

ABAJ/LAUREN SHAY

Tom Mullowney is a customs inspector at Kennedy Airport. ABA JOURNAL / OCTOBER 1, 1988 59



requirement covers more than 50 job titles ranging from clerical to profes sional and includes mail technicians, chemists and lawyers.

Any applicant testing positive for drug use will not be considered for a position at the agency, while current employees seeking promotions are

subject to dismissal. Two months after the drug tests

began, the National Treasury Em ployees Union, which represents 9,000 customs workers, filed suit in U.S. District Court for the Eastern District of Louisiana, alleging that the program violated the Fourth Amend ment. The suit argues that the collec tion of urine samples is a "search" and is therefore unreasonable unless there is reason to suspect an individual of drug use.

The district court agreed and halted the testing, ruling in Novem ber 1986 that the program was "de grading" and "overly intrusive." In his opinion, Judge Robert Collins said "excreting body fluids and body wastes is one of the most personal and private functions," and to test such wastes is "even more intrusive than a search of the home."

But on April 22, 1987, the 5th Circuit reversed. In a split 2-1 ruling, the court upheld the program, al though it acknowledged that "there are few activities in our society more personal or private than the passing of urine."

The court said the Customs Service had tried to minimize the in trusiveness of the program by not re

quiring observation of the employee during the test. It also viewed the program as "limited in total scope" because no discretion is exercised in deciding which employees are to be tested.

The program resumed in June of that year after the Supreme Court re fused the union's request for a stay.

The 9th Circuit undertook a sim ilar analysis in the railroad case but reached an opposite conclusion. At issue are regulations adopted by the Federal Railway Administration that require blood and urine tests be con ducted on all crew members of trains involved in accidents that cause death, major injury, property dam age or release of a hazardous sub stance.

The rules allow but do not re quire tests of workers who are sus

pected of contributing to an accident or who have committed a rule viola tion, such as speeding or passing through a stop signal. Those who fail the tests can be dismissed or sus

pended, and those who refuse are subject to a nine-month suspension.

Soon after they took effect in 1986, the regulations were chal lenged in court by the Railway Labor Executives' Association, a coalition of various unions. A district court up held the tests, but the appellate panel declared them unconstitutional in February 1988 because they were not grounded on a "particularized suspi cion" of drug use by an individual employee.

Urinalysis lets the government

discover a whole

range of information

"Accidents, incidents or rule vi olations, by themselves, do not create reasonable grounds for suspecting that testing will demonstrate alcohol or drug impairment in any one rail road employee, much less an entire train crew," Judge Thomas Tang wrote for the 2-1 panel. "We think when testing is undertaken to detect drug or alcohol abuse as a means of improving the safe operation of a railroad, it poses no insurmountable burden on the government to require individualized suspicion."

The Court will look closely at the contradictory appeals court rulings in crafting an answer to the drug test ing dilemma, but it also will rely heavily on its own Fourth Amend ment precedents. First the justices must answer the question: Is urinal ysis a search under the Fourth Amendment? If so, the Court must decide whether the search is reason able and thus exempt from the war rant requirement.

The extraction of blood has been

held to be a search. Schmerber v.

California, 384 U.S. 757 (1966). In that case, the justices concluded po lice did not need to obtain a warrant before administering a blood-alcohol test to a drunk driving suspect in volved in an automobile accident.

Lower courts have been in vir tual agreement that mandatory drug tests performed on public employees are, like blood tests, searches. Even if a urine specimen is collected under conditions that do not seriously in vade privacy, the courts have said, the analysis of the urine lets the govern ment inquire into a person's personal life and discover a whole range of in formation, from what prescription drugs one uses to whether a woman is pregnant.

But proponents of drug testing say that examination of urine cannot be a search because peo

ple have no expectation of privacy in their wastes.

"When you're talking about blood you're not talking about a waste product," says Vicki Marani of the Washington Legal Foundation, which has filed an amicus brief in the case on behalf of itself and two anti-drug organizations.

"Blood can only be extracted by an extrinsic means. But a waste prod uct is going to be voided from the body regardless and you're going to dispose of it regardless. Therefore your privacy interest is less."

Elaine Kaplan, who represents the Customs Service workers, ada

mantly disagrees. She says a urine test "is much more intrusive than the kinds of tests the court has permitted on less than probable cause grounds."

Even the Reagan administra tion, in briefs filed in connection with both the customs and railroad cases, conceded urinalysis is a search. But Justice Department lawyers say the searches are "reasonable," the sec

ond question the Court must con front in its analysis.

Lower courts are split on the is sue. While the bulk of them have up held drug testing programs in the. name of law enforcement or public safety, some have said that blanket screening can never be reasonable

and that there first must be "indivi dualized suspicion" of drug use.

It is a position with which the American Civil Liberties Union and

ABA JOURNAL / OCTOBER 1, 1988



ABAJ/LISA BERG

Elaine Kaplan

many labor unions agree. "Civil libertarians argue that no

tests could be reasonable if not based on information that would target an individual for suspicion," explains Burt Neuborne, a former ACLU legal director and now a professor at the New York University School of Law.

"It's conceivable the Court could draw some very fine lines as to what 'reasonable' means." If, for example,

they find "an overriding public con

cern," Neuborne says, testing would be considered reasonable.

Kaplan says her organization will urge the Court to stick with the prob able-cause standard. "The only time the Court has departed from the probable-cause requirement is when there is minimal intrusion and the government has demonstrated some

necessity to conduct the search," she says. "And given the fact there is no

ABAJ/LISA BERG

Lawrence Mann

evidence of widespread drug usage, customs hasn't demonstrated a need to depart from the probable-cause standard. If the Court disagrees, we would argue there must at least be some reasonable suspicion."

Justice Department lawyers, in contrast, contend a warrantless search may be valid in the absence of particularized suspicion. To deter mine if a search is appropriate, they say, courts must weigh the individu al's Fourth Amendment interests against the "legitimate governmental interests."

The government's interest pre vails in the Customs Service case, they say, because the drug tests pose a "minimal intrusion" on privacy, are administered only to employees who have applied for certain jobs, and be cause the test results are used only by the employer, not for the purposes of criminal prosecution.

The government interest in test ing railroad workers is even more

compelling, they argue, because rail roads are a heavily regulated indus try involving public safety.

Lawrence Mann, the lawyer for the railroad unions, admits his case is in trouble if the Court applies the "highly regulated industry excep tion" to the warrant requirement.

In a line of cases dating back sev eral years, the Court has said a state may inspect certain regulated indus tries such as coal mines and junk yards without having probable

ABA JOURNAL / OCTOBER 1, 1988 61

Courts of appeals divide on testing Federal appeals courts are divided

on the constitutionality of drug testing programs. Most have upheld testing that is conducted for reasons of public safety or law enforcement, but a few have said drug tests are only justified if there is individualized suspicion of drug use. Some of the key rulings include:

National Treasury Employees Union v. Von Raab, 816 F.2d 170 (1987) , cert, granted, No. 86-1879. The 5th Circuit upheld drug testing of job applicants for sensitive positions at the Customs Service, citing "strong governmental interest in employing individuals for key positions in drug enforcement who themselves are not drug users and the limited intrusiveness of this particular program."

Railway Labor Executives' Association v. Burnley 839 F.2d 575 (1988) , cert, granted, No. 87-1555. The 9th Circuit struck down mandatory testing of railroad crew members involved in accidents, saying such tests

may be allowed "only when specific articulable facts give rise to a reasonable suspicion that a test will reveal evidence of current drug or alcohol impairment."

McDonell v. Hunter, 809 F.2d 1302 (1987). The 8th Circuit upheld drug testing of employees at correctional institutions. Finding the interest in

prison security to be "central" and urinalysis "not nearly so intrusive as

body searches," the court held that the drug tests may be performed without individualized suspicion either "uniformly or by systematic random selection."

Shoemaker v. Handel, 795 F.2d 1136 (1986), cert, denied, No. 86-576 (Dec. 1,1986). The 3rd Circuit upheld regulations promulgated by the New Jersey racing commission that permit drug and alcohol testing for racing officials, jockeys, trainers and grooms. The court said the requirement was

appropriate in the horse-racing industry, which is already subject to

pervasive regulation. Jones v. McKenzie, 833 F.2d 335

(1987). The D.C. Circuit said that in the absence of probable cause, the district's school system could administer drug tests to bus attendants who are

responsible for supervising, attending and carrying handicapped children only if the tests are capable of showing "on the job" drug use.

Division 241 Amalgamated Transit Union v. Suscy, 538 F.2d 1264, cert, denied, 429 U.S. 1029 (1976). The 7th Circuit approved a drug and alcohol testing program for bus drivers who have been involved in serious accidents.

Andrea Neal



Conra l engineer Ricky Gates (inset) admits to having smoked marijuana just prior to the fatal Amtrak-Conrail train crash of 1987.

cause to believe evidence of a crime exists. So far, Mann notes, the excep tion has not been applied to individ uals.

"Even if they do apply it here," Mann says, "the Court will be faced with the issue of the necessity of the procedures they're imposing. We can make a sound argument that there are less stringent procedures that could be followed that would still accom plish the result of uncovering those who are impaired by alcohol or drugs."

Mann points out that the rail road unions do not oppose all testing, only those programs that tend to treat everyone including ticket takers and club-car waiters as suspects and

fail to pinpoint actual on-the-job im pairment. While blood-alcohol tests

can determine a person's intoxica tion level at the time the test is ad

ministered, technology does not yet exist to prove impairment from drug use.

Concern about drug testing, of course, is greatest in industries where mistakes can cost lives. Between 1972 and 1983, according to court docu ments, the nation's railroads experi enced at least 21 significant train accidents in which alcohol or drug use was a probable cause or contributing factor. Those accidents resulted in 25 fatalities, 61 injuries and property damage totaling $19 million.

A January 1987 collision of an Amtrak passenger train and Conrail freight train brought the point home with unusual force. The Conrail train, engineered by Ricky Gates, ran

through a series of stop signals near Baltimore and careened into the path of Amtrak's Colonial, which was ap proaching from behind at more than 100 mph. The ensuing crash killed the

Amtrak engineer and 15 passengers and injured 158 others.

Drug tests revealed that Gates and brakeman Edward Cromwell had smoked marijuana before the crash. The two men admitted sharing a joint as they watched the scenery from their Conrail cab, ignoring signals to slow down and stop. The test results were used to convict Gates of man slaughter.

Families of the victims have joined together in an amicus brief in Burnley to urge the Court to uphold drug testing, saying, "The existence of widespread drug and alcohol abuse

62 ABA JOURNAL / OCTOBER 1, 1988



by railroad employees is increasingly well-documented.

' '

It is widely believed that what ever the Court says about testing rail road workers will also apply to the airline industry, which has been tar geted by Congress for mandatory drug testing programs in the wake of scattered reports of drug use by pilots and air-traffic controllers.

Lawyers on both sides of the is sue agree that the case for drug test ing is strongest in transportation professions.

"I don't know if there are legal distinctions between the two cases," says the NTEU's Kaplan. "But I think in Burnley, people are significantly

more alarmed about railroads and drugs. There is a sense there is a drug problem in the railroad industry.

"The other difference is their testing is post-accident," Kaplan adds. "That might suggest some greater ex

igency than a promotions test." Marani, likewise, says the public

safety aspect of the railroad case may be a more compelling justification for testing. But she insists the govern

ment also has a strong interest in keeping its customs agents free of drugs. "These are people who are called upon to make judgments and often quick judgments. These are people who carry firearms. Someone who uses drugs doesn't have the kind of judgment necessary to operate in all these situations," she says.

The Court may have offered its own best hint of what it will do in a 1987 case involving the search of a

public employee's desk. O'Connor v.

Ortega, No. 85-530 (Mar. 31, 1987). In a plurality opinion by Justice

Sandra Day O'Connor, the Court said an employer need not have probable cause to conduct such a search but merely "reasonable ground for sus pecting that the search will turn up evidence that the employee is guilty of misconduct or that the search is necessary for a non-investigatory purpose such as to retrieve a file." It was the first ruling to set standards for public-employer searches.

Certainly, the Court's rulings in the two cases will have wide ramifications for transportation

workers and 16.9 million govern ment employees across the country. But while private employers are not subject to the restrictions the Bill of

Fourth Amendment precedents

The Supreme Court views most "bodily intrusions," such as blood testing or surgery, as searches subject to the Fourth Amendment's requirement of reasonableness.

In 1985, the court prohibited the forced removal of a bullet from the chest of an armed robbery suspect in Richmond, Va. "A compelled surgical intrusion into an individual's body for evidence," Justice William Brennan wrote, "implicates expectations of privacy and security of such magnitude that the intrusion may be 'unreasonable,' even if likely to produce evidence of a crime." Winston v. Lee, 470 U.S. 753 (1985).

In 1972, the Court said police made a Fourth Amendment search by taking and microscopically analyzing scrapings from a murder suspect's fingernails. But the Court said police did not need a warrant to conduct the search because it was clear that probable cause existed, the scraping of the nails was a minor intrusion and the evidence could easily have been destroyed. Cupp v. Murphy, 412 U.S. 291 (1972).

In 1966, the Court ruled that a state may require a blood test of an individual suspected of drunken driving without violating the person's privacy. The Court said drawing a small amount of blood was a "minor intrusion" justified by the value of the evidence to be obtained. Schmerber v. California, 384 U.S. 757 (1966).

The Court has dealt with bodily invasions in just one other context. Three years ago it ruled that border officials could detain a person suspected of smuggling drugs internally until the suspect had a bowel movement to produce the evidence. The Court, however, did not base the decision on Fourth Amendment analysis, but rather cited precedents holding that people searched at the border do not have the same constitutional rights as U.S. citizens. U.S. v. Montoya de Hernandez, 473 U.S.

531 (1985). Andrea Neal

Rights places on government, they too are watching closely because of the symbolic effect the rulings will have on their own efforts to keep drugs out of the workplace.

Legally, the decisions shouldn't have much impact, but the media certainly will portray the Court's de cisions as supporting or opposing drug tests in general, says Ohio Universi ty's Baum. "I'm sure decisions in fa vor of testing will be regarded as

something of a mandate even for the private sector. Decisions that oppose it might give unions and others a stronger position."

Legal questions aside, practical concerns about the tests may influ ence the justices. Stories abound of mislabeled urine samples, errors in test results and embarrassed employ ees unable to produce a sample on command.

Critics also complain that the tests are an ineffective way to com bat drug abuse. Because Customs Service workers know in advance that they will be tested, those who use drugs need merely abstain to en sure a negative result. And in the case of railroad workers, a positive test for drugs does not show that a worker was impaired at the time of an acci dent, merely that he had used drugs in the days preceding the event.

It should be noted that the cus toms and railroad testing programs have had varying degrees of success in uncovering drug users. Of 5,300 people tested by the Customs Service as of June 30, 1988, only six had po sitive results, just slightly more than .1 percent. Out of 1,508 railroad

workers tested between Feb. 10,1986 and Dec. 31, 1987, 10 tested positive for alcohol and 66 tested positive for drugs. Combined, they represented 5.8 percent of those tested.

No matter what the Court does, those who undergo the tests are not likely to forget them.

"I would say everybody who has taken one either finds it humiliating or degrading or asinine," says Mul lowney. "I've been with the Customs Service for 11 years. If they don't know me by now, they're never going to know me.

"When I arrest somebody I have to respect their rights," Mullowney adds. "I don't see why I should be subject to an inc scriminate test when I haven't done anything."

ABA JOURNAL / OCTOBER 1, 1988 63



Article Contentsp. 58p. 59p. 60p. 61p. 62p. 63

Issue Table of ContentsABA Journal, Vol. 74, No. 10 (OCTOBER 1, 1988), pp. 1-112, 115-136, 139-158Front MatterA Message From The PresidentDEATH PENALTY CASES: ENSURING FAIRNESS WHILE REDUCING DELAY [pp. 8-8]

Letters [pp. 12, 14, 16]CORRECTION: WEST, MEAD DATA CENTRAL SETTLE: Agreement ends three-year copyright dispute [pp. 16-16]NewsSAY 'JACK' 40,000 TIMES: Harassed lawyer sues Miami radio stations for $200 million [pp. 17-17]McCLESKEY HIT: Criminologist: Court ignored 'starkest' race bias evidence [pp. 18-18]REFORM CALL: Powell on capital punishment [pp. 19-19]LSC BACKERS CITE HARASSMENT: But presidential elections seen as light at end of tunnel [pp. 20-20]AND NOW THE STEROID DEFENSE? Murder defendants allege the drug produces psychotic side effects [pp. 22, 24]AIDSA DILEMMA FOR EMPLOYERS: Businesses need to avoid discrimination while addressing workers' fears [pp. 24-24]THERE'S A PC ON MY DESK! In the future, everyone will have a computer [pp. 26-26]WHO LIKES LAWYER ADS? Consumers do, but lawyers aren't so sure [pp. 28-28]HEADS UP! Malpractice alert issued [pp. 28-28]MARYLAND REFERENDUM A PISTOL: Gun control opponents may be shooting selves in foot [pp. 30-30]LAW FIRM ROLE MODELS: Partners should take lead in teaching associates [pp. 31-31]CHURNING YOUR BROKER: How to identify excessive trading [pp. 32-32]QUOTES [pp. 34-34]SCREENING BY ABA OK: Court dismisses challenge [pp. 35-35]MANDATORY BARS SHAKEN: Wisconsin ruling may be first shot in long war [pp. 36-36]AN ENIGMA WRAPPED IN A RIDDLE? Studies provide ammunition for both sides in tort reform debate [pp. 38-39]USEFUL TRIAL TIPS: Denver lawyer shares advice at program [pp. 39-39]KNOW YOUR CLIENT'S PSYCHOLOGY: Use mental-health professionals in custody cases [pp. 40-40]

At Issue: CIVIL RICO: Is substantial reform necessary? [pp. 42-43]Supreme Court Preview [pp. 44-44]Supreme Court ReportOF LAWYERS AND JUDGES [pp. 46, 48, 50-51]

The Candidates Respond [pp. 52-54, 56-57]Mandatory Drug Testing [pp. 58-63]The New Tax Laws [pp. 66-70]The Genius of Ed Williams [pp. 72-75]Through the Jurors' Eyes [pp. 78-81]The Trial of an All-American [pp. 84-88]LitigationTHE GIGGLE TEST [pp. 90, 92]

Lawyer LIFESTYLESNO FEAR OF FLYING [pp. 94-95]

Trends in the Law [pp. 96, 98, 100, 102]Speaking and WritingON LEGAL STYLE [pp. 104, 106]

Your FinancesMAKING MONEY THROUGH REHABS [pp. 108, 110, 112]

New Products [pp. 116-116]EthicsTHE RIGHT CHOICE [pp. 118-118]

Management SolutionsPCs IN A P-I PRACTICE [pp. 120, 122]

Books for LawyersLEGAL FICTIONS [pp. 124, 126]THE WRITE STUFF [pp. 126-128]THE TORT LOTTERY [pp. 128-130]

YOUR ABARACIAL BIAS, SEXISM UNDER FIRE: House debates McCleskey, private clubs, professionalism [pp. 139-140]PRO BONO POLICY PASSED [pp. 140-141]RAVEN: JUSTICE NOT A LUXURY [pp. 142-142]MacCRATE: END CRONYISM [pp. 143-143]SUBSTANCE ABUSE: New commission will aid impaired lawyers [pp. 144-144]GENDER BIAS: ABA commission issues first report [pp. 144-144]ABA Profile: CRIMINAL JUSTICE SECTION [pp. 145-145]PROMOTING PROFESSIONALISM: ABA committee is catalyst for Goal Five proposals [pp. 146-146]Washington Report: ABA URGES RICO REFORM [pp. 147-147]ABA AWARDS ANNOUNCED [pp. 148-149]MEETING DATES [pp. 150-150]U.N. DUES OVERDUE [pp. 150-150]SECTION NAME CHANGE [pp. 150-150]ELECTION RESULTS [pp. 150-150]

War Stories [pp. 158-158]Back Matter

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