Criminal Procedure keyed to Weinreb
Skinner v. Railway Labor Executives’ Association
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Various rules applicable to railway employees were promulgated in order to combat both the possession of alcohol or being intoxicated while working. Rules were also promulgated to stop the use of drugs. “These restrictions are embodied in ‘Rule G,’ an industry-wide operating rule promulgated by the Association of American Railroads, and are enforced, in various formulations, by virtually every railroad in the country. The customary sanction for Rule G violations is dismissal.” “In July 1983, the FRA expressed concern that these industry efforts were not adequate to curb alcohol and drug abuse by railroad employees. The FRA pointed to evidence indicating that on-the-job intoxication was a significant problem in the railroad industry.” ” In view of the obvious safety hazards of drug and alcohol use by railroad employees, the FRA announced in June 1984 its intention to promulgate federal regulations on the subject.” Further, “[c]omments submitted in response to [these findings] indicated that railroads were able to detect a relatively small number of Rule G violations, owing, primarily, to their practice of relying on observation by supervisors and co-workers to enforce the rule.” “After reviewing further comments from representatives of the railroad industry, labor groups, and the general public, the FRA, in 1985, promulgated regulations addressing the problem of alcohol and drugs on the railroads.” “The regulations further prohibit those employees from reporting for covered service while under the influence of, or impaired by, alcohol, while having a blood alcohol concentration of 0.04 or more, or while under the influence of, or impaired by, any controlled substance. The regulations do not restrict, however, a railroad’s authority to impose an absolute prohibition on the presence of alcohol or any drug in the body fluids of persons in its employ, and, accordingly, they do not ‘replace Rule G or render it unenforceable.’ ” “To the extent pertinent here, two subparts of the regulations relate to testing. Subpart C, which is entitled ‘Post-Accident Toxicological Testing,’ is mandatory. It provides that railroads ‘shall take all practicable steps to assure that all covered employees of the railroad directly involved . . . provide blood and urine samples for toxicological testing by FRA,’ upon the occurrence of certain specified events. Toxicological testing is required following a ‘major train accident,’ which is defined as any train accident that involves (i) a fatality, (ii) the release of hazardous material accompanied by an evacuation or a reportable injury, or (iii) damage to railroad property of $500,000 or more. The railroad has the further duty of collecting blood and urine samples for testing after an ‘impact accident,’ which is defined as a collision that results in a reportable injury, or in damage to railroad property of $50,000 or more. Finally, the railroad is also obligated to test after ‘[a ]ny train incident that involves a fatality to any on-duty railroad employee.’ ” “After occurrence of an event which activates its duty to test, the railroad must transport all crew members and other covered employees directly involved in the accident or incident to an independent medical facility, where both blood and urine samples must be obtained from each employee. After the samples have been collected, the railroad is required to ship them by prepaid air freight to the FRA laboratory for analysis. There, the samples are analyzed using ‘state-of-the-art equipment and techniques’ to detect and measure alcohol and drugs. The FRA proposes to place primary reliance on analysis of blood samples, as blood is ‘the only available body fluid . . . that can provide a clear indication not only of the presence of alcohol and drugs but also their current impairment effects.’ Urine samples are also necessary, however, because drug traces remain in the urine longer than in blood, and in some cases it will not be possible to transport employees to a medical facility befor e the time it takes for certain drugs to be eliminated from the bloodstream. In those instances, a ‘positive urine test, taken with specific information on the pattern of elimination for the particular drug and other information on the behavior of the employee and the circumstances of the accident, may be crucial to the determination of” the cause of an accident.’ ” “The regulations require that the FRA notify employees of the results of the tests and afford them an opportunity to respond in writing before preparation of any final investigative report. Employees who refuse to provide required blood or urine samples may not perform covered service for nine months, but they are entitled to a hearing concerning their refusal to take the test.” Moreover, “Subpart D of the regulations, which is entitled ‘Authorization to Test for Cause,’ is permissive. It authorizes railroads to require covered employees to submit to breath or urine tests in certain circumstances not addressed by Subpart C. Breath or urine tests, or both, may be ordered (1) after a reportable accident or incident, where a supervisor has a ‘reasonable suspicion’ that an employee’s acts or omissions contributed to the occurrence or severity of the accident or incident, in the event of certain specific rule violations, including noncompliance with a signal and excessive speeding. A railroad also may require breath tests where a supervisor has a ‘reasonable suspicion’ that an employee is under the influence of alcohol, based upon specific, personal observations concerning the appearance, behavior, speech, or body odors of the employee. Where impairment is suspected, a railroad, in addition, may require urine tests, but only if two supervisors make the appropriat e determination, and, where the supervisors suspect impairment due to a substance other than alcohol, at least one of those supervisors must have received specialized training in detecting the signs of drug intoxication.” “Subpart D further provides that whenever the results of either breath or urine tests are intended for use in a disciplinary proceeding, the employee must be given the opportunity to provide a blood sample for analysis at an independent medical facility. If an employee declines to give a blood sample, the railroad may presume impairment, absent persuasive evidence to the contrary, from a positive showing of controlled substance residues in the urine. The railroad must, however, provide detailed notice of this presumption to its employees, and advise them of their right to provide a contemporaneous blood sample. As in the case of samples procured under Subpart C, the regulations set forth procedures for the collection of samples, and require that samples ‘be analyzed by a method that is reliable within known tolerances.’ ” The Respondents, Railway Labor Executives’ Association and many of its member labor groups (the “Respondents”) brought suit seeking to enjoin the FRA’s regulations on various statutory and constitutional grounds. The District Court granted the Petitioners, Skinner and others (the “Petitioners”) summary judgment. The Ninth Circuit reversed and certiori was granted.
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