Kaley T. Crum v. Quinton L. Reinhardt

Summary

The United States District Court for the Western District of Arkansas granted Defendant Quinton L. Reinhardt’s motion for summary judgment and denied Plaintiff Kaley T. Crum’s cross-motion in a 42 U.S.C. § 1983 action. The court held that, even assuming a warrantless urine test was sufficiently intrusive to require valid consent, the asserted Fourth Amendment limitation was not clearly established, entitling the defendant to qualified immunity. The complaint was dismissed with prejudice.

Holdings

1. Even assuming that a urine test is sufficiently intrusive that it cannot be administered without a warrant or valid consent as a search incident to arrest, that proposition was not clearly established at the time of Defendant's conduct.
2. Defendant was entitled to qualified immunity because Plaintiff could not establish the clearly established prong of the qualified-immunity analysis.
3. Defendant's motion for summary judgment was granted, Plaintiff's motion was denied, and the complaint was dismissed with prejudice.

Questions Presented

1. Whether the warrantless collection of Plaintiff's urine sample violated the Fourth Amendment.
2. Whether Plaintiff's consent to the urine test was voluntary despite the implied-consent form and asserted criminal consequences for refusal.
3. Whether Defendant was entitled to qualified immunity because it was not clearly established that a warrantless urine test in these circumstances fell outside the search-incident-to-arrest exception.
4. Whether either party was entitled to summary judgment.

Disposition

dismissed