Kittle-Aikeley v. Claycomb, No. 13-3264 (8th Cir. 2015)
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Linn State's Board of Regents adopted a mandatory drug screening policy. Plaintiffs filed suit challenging the drug screening policy. In Barrett v. Claycomb, a panel of this court reviewed an interlocutory appeal, discussing, and ultimately reversing, the grant of a preliminary injunction in favor of plaintiffs on their facial challenge to the drug testing policy. On remand, plaintiffs clarified their claims to assert an as-applied challenge to the very same policy. The district court, in part, permanently enjoined Linn State from conducting any further collection, testing, or reporting. On appeal, Linn State challenged the district court's grant of a permanent injunction and subsequent grant of attorneys' fees in favor of plaintiffs. The court concluded that, on balance, testing the entire student population entering Linn State is reasonable and
hence constitutional and an effective means of addressing Linn State's interest in providing "a safe, healthy, and productive environment for everyone who learns and works at LSTC by detecting, preventing, and deterring drug use and abuse among students." Accordingly, the court reversed and remanded for dismissal of the case.
Court Description: Beam, Author, with Bye and Smith, Circuit Judges] Civil case - Drug Testing. For the court's prior opinion in the matter, see Barrett v. Claycomb, 705 F.3d 315 (8th Cir. 2013)where the court reversed the grant of a preliminary injunction in favor of plaintiffs on their facial challenge to Linn State Technical College's drug-testing policy. On remand, plaintiffs clarified their claims to assert an "as-applied" challenge to the same policy, and the district court enjoined the policy in part and prohibited the testing of students who were not enrolled in five enumerated programs. The district court erred in enjoining the policy as to the students not enrolled in the five enumerated programs as, on balance, testing the entire student population entering the college is reasonable and hence a constitutional and effective means of addressing the college's interest in providing a safe, healthy workplace given the fact that the students at this particular technical college are engaged in safety-sensitive and potentially dangerous activities. Judge Bye, dissenting.
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