Friday, November 1, 2013

Trinity Industries, Inc. v. OSHRC case brief

Trinity Industries, Inc. v. OSHRC case brief
16 F.3d 1455 (1994)

CASE SYNOPSIS
Petitioner manufacturer appealed an order of the Occupational Safety and Health Review Commission affirming an administrative law judge's decision to deny petitioner's motion to suppress evidence in a hearing in which it challenged certain citations alleging violations of Occupational Safety and Health Administration standards.

CASE FACTS
An employee filed a formal complaint against petitioner manufacturer with the Occupational Safety and Health Administration (OSHA) alleging certain safety violations. OSHA obtained warrant to inspect petitioner's facility, which was challenged by petitioner. OSHA conducted the inspection of petitioner's facility, and subsequently issued citations for specific alleged violations of OSHA standards. An administrative law judge denied petitioner's motion to suppress evidence, the Occupational Safety and Health Review Commission affirmed, and petitioner appealed.

DISCUSSION
  • The court held that a full-scope inspection authorized by a single warrant initially obtained only on the basis of an employee complaint was improper and the Secretary should have secured a search warrant limited in scope to the employee complaint that triggered the inspection. 
  • The court further held, however, that the Secretary relied in objectively reasonable good faith on a facially valid warrant in conducting the full-scope inspection of the petitioner's facility, and thus the good faith exception to the exclusionary rule applied.

OUTCOME

The court affirmed the decision of the Occupational Safety and Health Review Commission on the basis that the Occupational Safety and Health Administration executed its full-scope inspection of the petitioner manufacturer's facility in a manner that the agency believed in objectively reasonable good faith to be authorized by the facially valid warrant it had obtained.

Recommended Supplements for Administrative Law Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)

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