Pyle v. Woods

The Utah Controlled Substance Database was created in 1995 to record data regarding every controlled-substance prescription dispensed in Utah to persons outside inpatient healthcare facilities. The Utah Controlled Substance Database Act, which authorized the database’s creation, also authorized local law enforcement to access the database without a warrant. In 2013, detective James Woods (defendant) was tasked with identifying the person responsible for the theft of various medications, including opioids, from ambulances owned by Utah’s United Fire Authority (UFA). When Woods received a list of the 480 UFA employees with ambulance access, he searched the database for each employes’s prescription records in an attempt to determine whether any employees had opioid dependencies. Based on the warrantless database search, Woods came to suspect UFA employees Ryan Pyle and Marlon Jones (plaintiffs), although neither employee was ultimately prosecuted for the thefts. Pyle and Jones sued Woods, alleging that his warrantless database activity violated their Fourth Amendment right to freedom from unreasonable searches. Woods asserted qualified immunity as a defense, arguing that it shielded from any civil liability for his conduct. The district court agreed and dismissed the claims against Woods. Pyle and Jones appealed.