SmithKline Beecham Corp. v. Doe
Texas Supreme Court
903 S.W.2d 347 (1995)
- Written by Kelsey Libby, JD
Facts
Jane Doe (plaintiff) received a job offer from Quaker Oats Company (Quaker) for a marketing-assistant position. The offer was conditioned on Doe passing a drug test. SmithKline Beecham Clinical Laboratories, Inc. (SmithKline) (defendant) processed Doe’s drug test, which was positive for opiates. Quaker rescinded Doe’s job offer due to her positive test. Doe later claimed that the positive result was due to her consumption of poppy-seed muffins, which was a scientifically valid explanation. SmithKline was aware that its drug tests could not distinguish between poppy seeds and illegal opiates and did not warn or communicate that fact to Quaker or Doe. It was unknown whether Quaker would have made a different decision regarding Doe’s employment if it had known that the positive result was due to poppy seeds. Doe sued SmithKline for negligence related to the drug test. The trial court granted summary judgment for SmithKline, and the appellate court reversed. SmithKline appealed. Doe conceded that the test correctly identified the presence of opiates in her sample but argued that SmithKline had a duty to warn her and Quaker that the ingestion of poppy seeds could result in a positive test.
Rule of Law
Issue
Holding and Reasoning (Hecht, J.)
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