Luedtke v. Nabors Alaska Drilling

768 P.2d 1123 (1989)

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Luedtke v. Nabors Alaska Drilling

Alaska Supreme Court
768 P.2d 1123 (1989)

Facts

Paul Luedtke (plaintiff) worked on a drilling rig for Nabors Alaska Drilling, Inc. (Nabors) (defendant). Luedtke worked as a driller, a position that oversaw the work of an entire drilling crew on the rig. Although Luedtke was initially a union member, he was not in a union after Nabors broke the union. After that, Luedtke had no employment agreement for the rest of his time with Nabors. Nabors twice cited Luedtke for violating the company’s drug and alcohol policy, although these violations did not result in termination. Just before Luedtke took a several weeks’ vacation, Nabors required him to submit for a physical exam. Luedtke understood the purpose of this exam to be to determine his fitness for service and did not know it would involve a drug test. Luedtke voluntarily gave a urine sample, thinking the sample was kidney related. Two weeks later, Nabors announced a new drug policy. Luedtke’s urine tested positive for cannabinoids, and Nabors requested that Luedtke take a second test. Luedtke declined and was terminated. Luedtke sued Nabors on the theories that Nabors (1) violated his right to privacy under the Alaska Constitution, (2) violated the wrongful-termination doctrine, and (3) violated the common-law doctrine of the right to privacy. After Nabors succeeded in the trial court, Luedtke appealed.

Rule of Law

Issue

Holding and Reasoning (Compton, J.)

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