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Skinner v. Railway Labor Executives’ Ass'n | 489 U.S. 602 (1989)
The Fourth Amendment guarantees the right to be free from unreasonable searches and seizures. However, if the government has a unique interest, called a special need, that makes getting a warrant unrealistic, certain suspicionless searches are permitted. In Skinner versus Railway Labor Executives’ Association, an agency’s mandatory drug-testing regulation hit a third rail with employees.
The Federal Railroad Administration promulgated regulations to detect and deter alcohol and drug abuse in railroad work. The regulatory scheme included two provisions pertaining to toxicology testing. First, railroads were required to transport all crew members to an independent testing facility for blood and urine sampling after major train accidents, impact accidents, or crew member deaths. Second, railroads were permitted to require crew members to submit to breath and urine tests upon reasonable suspicion or upon a reportable incident or rule violation.
The Railway Labor Executives’ Association sued Samuel K. Skinner, the Secretary of Transportation, and others in the United States District Court for the Northern District of California. The association argued, in part, that the regulation’s testing provisions violated the privacy rights of railroad employees. The district court disagreed and granted summary judgment in the agency’s favor. The association appealed to the United States Court of Appeals for the Ninth Circuit, which reversed. The United States Supreme Court then granted cert.
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