Garrett v. Clarke

552 F. Supp. 3d 539 (2021)

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Garrett v. Clarke

United States District Court for the Eastern District of Virginia
552 F. Supp. 3d 539 (2021)

Facts

Jacoby Garrett (plaintiff) worked as a telecommunications network coordinator for the Virginia Department of Corrections (VDOC) (defendant). Garrett’s job duties included assisting other VDOC employees with their mobile devices. Garrett did not monitor, confine, or oversee any inmates, but Garrett had occasional casual encounters with inmates at VDOC headquarters or if Garrett was performing work at a VDOC correctional facility. VDOC’s operating procedures provided that all employees were subject to random drug testing and that an employee’s failure to report for random drug testing was grounds for termination. In June 2018, a VDOC personnel assistant told Garrett that Garrett had been selected for drug testing. Garrett agreed to take the test, but before the assistant could get the testing supplies ready, Garrett learned that his manager was looking for Garrett. Garrett told the assistant, and the assistant told Garrett that the assistant would test Garrett “next time.” However, the next day, the assistant reported that Garrett had refused the drug test. VDOC placed Garrett on predisciplinary leave and ultimately fired Garrett for the purported refusal to take the test. Garrett brought an action in federal court against VDOC, VDOC Director Harold Clarke, and two other VDOC officials (defendants), asserting that VDOC’s random-drug-testing policy violated Garrett’s Fourth Amendment rights. Garrett asserted that although random, suspicionless drug testing for government employees in safety-sensitive positions was an exception to the Fourth Amendment’s warrant requirement, Garrett’s position was not a safety-sensitive position. Clarke and the other VDOC officials moved to dismiss Garrett’s claims against them, asserting qualified immunity. Clarke and the officials argued that Garrett had not alleged a constitutional violation because the government’s interest in drug testing Garrett outweighed Garrett’s privacy interest, given Garrett’s alleged access to sensitive information and contact with inmates. However, nothing in Garrett’s complaint alleged that Garrett had access to sensitive information in his position.

Rule of Law

Issue

Holding and Reasoning (Payne, J.)

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