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Thompson v. Owens

United States Court of Appeals, Third Circuit
Nov 15, 1989
889 F.2d 500 (3d Cir. 1989)

Summary

holding that positive urinalysis results meet the "some evidence" standard

Summary of this case from Fernandez v. Espinosa

Opinion

No. 89-5149.

Argued July 11, 1989.

Decided November 15, 1989.

Robin Jean Foor (argued), Keystone Legal Services, Inc., State College, Pa., for appellant.

Ernest D. Preate, Jr., Atty. Gen., Calvin R. Koons (argued), Sr. Deputy Atty. Gen., John G. Knorr, III, Chief Deputy Atty. Gen., Harrisburg, Pa., for appellees.

Appeal from the United States District Court for the Middle District of Pennsylvania.

Before HIGGINBOTHAM, BECKER and NYGAARD, Circuit Judges.


OPINION OF THE COURT


Appellant David Thompson, an inmate confined at the State Correctional Institution at Rockview, Pennsylvania, brought this civil rights class action in the district court for the Middle District of Pennsylvania against various correctional officials, complaining that his due process rights had been violated by the officials' failure to provide complete chain of custody evidence at his misconduct hearing. Appellant tested positive on his urinalysis drug test and was convicted of misconduct. As a result of the conviction, appellant suffered a significant loss of benefits. He alleged in his complaint that, because there was no evidence of the chain of custody of his urine sample, test results based upon it could not be placed into evidence in the record of proceedings. Adopting the Magistrate's report, the district court dismissed the complaint, concluding that despite the absence of "chain of custody" evidence, the positive results of appellant's urinalysis tests amounted to "some" evidence sufficient to support a finding of misconduct and to satisfy due process (App. 49-55).

The quantum of evidence necessary in the context of prisoner disciplinary proceedings was described by the Supreme Court in Superintendent v. Hill, 472 U.S. 445, 105 S.Ct. 2768, 86 L.Ed.2d 356 (1985):

We hold that the requirements of due process are satisfied if some evidence supports the decision by the prison disciplinary board to revoke good time credits. This standard is met if "there was some evidence from which the conclusion of the administrative tribunal could be deduced. . . ." Ascertaining whether this standard is satisfied does not require examination of the entire record, independent assessment of the credibility of witnesses, or weighing of the evidence. Instead, the relevant question is whether there is any evidence in the record that could support the conclusion reached by the disciplinary board. . . ." We decline to adopt a more stringent evidentiary standard as a constitutional requirement.

Id. at 455-56, 105 S.Ct. at 2774 (emphases added and citations omitted). This case is controlled by Hill.

Appellant does not allege that prison officials tampered with the samples. Nor does he allege that the prison officials failed to follow their own procedures. Appellant merely argues that if officials do not submit a complete chain of custody account for the samples, any test results based on those samples must be considered unreliable. However appealing this argument may be, it does not present a viable constitutional claim. The due process requirements in this context are minimal, and they are met here. Positive urinalysis results based on samples that officials claim to be appellant's constitute some evidence of appellant's drug use. A chain of custody requirement would be nothing more or less than an "independent assessment" into the reliability of the evidence, and Hill tells us, explicitly, that such a "credibility" determination is not required. See id. at 455, 105 S.Ct. at 2774.

The matter referred to in Judge Higginbotham's concurring opinion was raised by the panel, sua sponte.

The judgment of the district court will be affirmed.


Common sense and a concern for fairness are the prerequisites for any rational administrative process. Our common experience teaches us that through mere negligence administrative errors can occur in the processing of files or specimens; such errors can occur without any intent to tamper or to create erroneous results.

Our civil dockets are burgeoning with allegations that patients have become ill and that some have even died because of an error in test results or because the laboratory's "findings" were attributed to the wrong patient. Prison administrators are not immune to the "foul ups" that occur in all other organizations. Human errors are possible everywhere. Thus, a careful administrator on his or her own would develop specific guidelines to establish an unmistakable chain of custody in order to avoid injury to the innocent.

While I am concerned with common sense and administrative responsibility, the Supreme Court has stressed the wide discretion prison authorities have in dealing with matters of prison security. See Bell v. Wolfish, 441 U.S. 520, 548, 99 S.Ct. 1861, 1879, 60 L.Ed.2d 447 (1979) ("courts should ordinarily defer to [prison authorities'] expert judgment in such matters [as prison discipline and institutional security]"). Only recently, our Court was reversed in a 5-4 decision by the Supreme Court in O'Lone v. Estate of Shabazz, 482 U.S. 342, 107 S.Ct. 2400, 96 L.Ed.2d 282 (1987). The Court, speaking through Chief Justice Rehnquist again stressed:

In considering the appropriate balance of these factors, we have often said that evaluation of penological objectives is committed to the considered judgment of prison administrators, "who are actually charged with and trained in the running of the particular institution under examination." To ensure that courts afford appropriate deference to prison officials, we have determined that prison regulations alleged to infringe constitutional rights are judged under a "reasonableness" test less restrictive than that ordinarily applied to alleged infringements of fundamental constitutional rights. We recently restated the proper standard: "[W]hen a prison regulation impinges on inmates' constitutional rights, the regulation is valid if it is reasonably related to legitimate penological interests." This approach ensures the ability of officials "to anticipate security problems and to adopt innovative solutions to the intractable problems of prison administration," and avoids unnecessary intrusion of the judiciary into problems particularly ill-suited to "resolution by decree."

482 U.S. at 349-350, 107 S.Ct. at 2404 (citations omitted).

The majority on this panel is probably correct that, under the current constitutional standards, the requirement of a chain of custody in cases of this type need not be met, but I hope that prison administrators will consider what is fair and not merely what avoids constitutional infraction. The "some evidence" standard articulated by the majority means necessarily that there is always the substantial possibility that an injustice is done because a test result is inaccurate or the wrong specimen got into the "chain of custody." But the teaching of Shabazz is that the real possibility of a mistake by the laboratory in its chain of custody does not warrant any safeguards to prevent injustices to inmates who desire to challenge the results by requiring defendant to establish proof in the chain of custody.

In response to our inquiry at oral argument, the Attorney General has replied:

The Department of Corrections Request for Proposal dated February 6, 1987, pursuant to which a contract for laboratory testing services was awarded [provided in] paragraph 7(D) of the document . . . that a chain of custody procedure be used for all drug/alcohol screening requests.

If the appellees are not implementing the Department's own policy, one must ask why would anyone with a sense of fairness would not faithfully follow its own rules when a person's liberty is at stake. If the appellees are making certain that these procedures are being complied with, it is surprising that they did not want to provide evidence as to the chain of custody when the issue was raised. While the appellees' conduct is a scintilla short of unconstitutionality under the strictures of Bell v. Wolfish and Shabazz, it is my hope that the appellees and their counsel will recognize that winning a lawsuit is not the equivalent of an affirmation that they have been fair or that they have exemplified that important but rare quality — common sense.

I concur in the judgment of affirmation.


Summaries of

Thompson v. Owens

United States Court of Appeals, Third Circuit
Nov 15, 1989
889 F.2d 500 (3d Cir. 1989)

holding that positive urinalysis results meet the "some evidence" standard

Summary of this case from Fernandez v. Espinosa

finding that prisoner's due process rights had not been violated when he lost "significant benefits" in prison after urinalysis revealed he had consumed drugs. Though the prison could not establish a chain of custody for the urine test, the positive test nevertheless met the "some evidence" standard

Summary of this case from Griffin v. Holt

concluding that due process requirements at prisoner disciplinary hearings are minimal

Summary of this case from Aliamirnazmi v. Scism

concluding that due process requirements at prisoner disciplinary hearings are minimal

Summary of this case from Amirnazmi v. Scism

In Thompson, we held that these requirements are met if there is "some evidence" in the record of the disciplinary proceeding showing that the sample belonged to the inmate charged with the disciplinary infraction.

Summary of this case from Elkin v. Fauver

dismissing habeas petition because "positive urinalysis results on samples that officials claim to be [the inmate's] constitute some evidence" and "independent assessment" of the urinalysis is "not required"

Summary of this case from Bennett v. Warden of Allenwood

dismissing habeas petition because "positive urinalysis results on samples that officials claim to be [the inmate's] constitute some evidence" and "independent assessment" of the urinalysis is "not required"

Summary of this case from Berry v. Kirby

In Thompson v. Owens, the Third Circuit held that "[p]ositive urinalysis results based on samples that officials claim to be [the plaintiff's] constitute some evidence of [the plaintiff's] drug use.

Summary of this case from Singleton v. Hernandez

In Thompson, the inmate who, just like Petitioner, "tested positive on his urinalysis drug test and was [disciplined for the] misconduct" of illegal use of narcotics, asserted that the laboratory test results of his urinary sample should not have been introduced and relied upon during his disciplinary hearing because "there was no evidence of the chain of custody of his urine sample."

Summary of this case from Wilson v. Hollingsworth

noting that "[t]he due process requirements in this context are minimal"

Summary of this case from Bleau v. Diguglielmo

In Thompson, the court considered whether the failure of certain prison officials' to provide complete chain of custody evidence at a misconduct hearing violated due process.

Summary of this case from Wade v. Farley, (N.D.Ind. 1994)

In Thompson, the inmate "tested positive on his urinalysis drug test and was convicted of misconduct [and]... suffered a significant loss of benefits.

Summary of this case from Wade v. Farley, (N.D.Ind. 1994)
Case details for

Thompson v. Owens

Case Details

Full title:DAVID THOMPSON, ON HIS OWN BEHALF AND ON BEHALF OF OTHERS SIMILARLY…

Court:United States Court of Appeals, Third Circuit

Date published: Nov 15, 1989

Citations

889 F.2d 500 (3d Cir. 1989)

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