Barrett v. Claycomb

In Barrett v. Claycomb, 705 F.3d 315 (8th Cir. 2013), based on the evidence presented in support of Appellees' motion for a preliminary injunction on their facial challenge, the Court determined many points that remain relevant and buttress our instant analysis: (1) the public has a valid interest in deterring drug use among students engaged in programs posing significant safety risks to others, 705 F.3d at 322; (2) "some college students that attend Linn State have a diminished expectation of privacy because they are seeking accreditation in heavily regulated industries and industries where drug testing, in practice, is the norm," id. at 323; (3) Linn State's testing procedures significantly minimize the intrusiveness of Linn State's drug-screening program and are relatively noninvasive, thus the invasion of students' privacy is not significant, id.; (4) the need to prevent and deter the substantial harm that can arise from a student under the influence of drugs while engaging in a safety-sensitive program provides the necessary immediacy for Linn State's testing policy, id.