Monday, December 23, 2013

Skinner v. Railway Labor Executives’ Association case brief

Skinner v. Railway Labor Executives’ Association case brief summary
489 U.S. 602 (1989)

Petitioner Federal Railroad Administration appealed an order of the United States Court of Appeals for the Ninth Circuit that reversed a judgment that found the governmental interest in promulgated regulations, 49 C.F.R. §§ 219.101- 219.301(c)(2) (1987), outweighed the U.S.Constitutional Amendment IV rights of employees who were covered under the Hours of Service Act, 45 U.S.C.S. § 61 et seq.

  • The Supreme Court reversed a judgment that found petitioner Federal Railroad Administration's promulgation of regulations 49 C.F.R. § 219.101- 219.301(c)(2) (1987), under the Federal Railroad Safety Act (Act), 45 U.S.C.S. § 431(a), violated the U.S. Constitutional Amendment IV rights of employees covered by the Hours of Service Act,45 U.S.C.S. § 61 et seq. 
  • The court found the alcohol and drug tests under Subparts C and D of petitioner's regulations were reasonable within the meaning of U.S. Constitutional Amendment IV and no warrants or reasonable suspicion were required before any testing. 
  • The court held that railroad employers had limited discretion under the regulations and there was a strong governmental interest to regulate railroad employees' conduct to ensure public safety. 
  • The tests were not considered intrusive because there was a diminished expectation of privacy on the information relating to the physical condition of covered employees and to reasonable means of procuring the information because the industry was highly regulated for safety. 
  • The court found that most railroads required periodic physical exams for certain employees.
The order in favor of respondent was reversed.

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