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Keywords

subpoenaappealcompliancecriminal procedureseizure

subpoenaappealhearingwillcompliance

Related Cases

U.S. v. Comprehensive Drug Testing, Inc., 621 F.3d 1162, 2010 Daily Journal D.A.R. 11,941, 2010 Daily Journal D.A.R. 14,440

Facts

In 2002, the federal government began an investigation into the Bay Area Lab Cooperative (Balco) for allegedly providing steroids to professional baseball players. As part of this investigation, the government obtained search warrants and subpoenas for drug testing records from Comprehensive Drug Testing, Inc. (CDT), which administered a drug testing program for Major League Baseball players. CDT and the players sought the return of property seized under these warrants, arguing that the government had violated their constitutional rights by overreaching in its seizure of records. The district courts in California and Nevada ruled in favor of CDT and the players, leading to a consolidated appeal by the government.

In 2002, the federal government commenced an investigation into the Bay Area Lab Cooperative (Balco), which it suspected of providing steroids to professional baseball players. That year, the Major League Baseball Players Association (the Players) also entered into a collective bargaining agreement with Major League Baseball providing for suspicionless drug testing of all players.

Issue

Whether the government was barred from contesting the determination that it had callously disregarded the constitutional rights of the affected players and whether the district courts abused their discretion in ordering the return of seized property and quashing the government's subpoenas.

Rule

The doctrine of issue preclusion prevents a party from relitigating an issue that has already been determined in a final judgment in a prior case. In this context, the government was barred from contesting findings that it had failed to comply with the procedures outlined in the warrants and had acted with callous disregard for the players' rights. The Federal Rules of Criminal Procedure allow for the return of property seized unlawfully, and the courts have discretion to quash subpoenas if compliance would be unreasonable or oppressive.

Analysis

The court found that the government had failed to follow the procedures required by the warrants, which were designed to protect the privacy of individuals whose records were not the subject of the investigation. The government's actions in seizing records beyond those for which it had probable cause demonstrated a disregard for the constitutional rights of the players. The district courts' decisions to return the seized property and quash the subpoenas were upheld based on the preclusive effect of earlier rulings and the government's misconduct.

In appealing district court order requiring it to return property seized pursuant to a search warrant for urine samples on which suspicionless drug tests of professional baseball players had been performed, with the exception of materials pertaining to ten players identified in the warrant, government was barred under the doctrine of issue preclusion from contesting determination that it callously disregarded the affected players' constitutional rights, and that it unreasonably refused to follow the procedures set forth in United States v. Tamura upon learning that drug-testing records for the ten athletes named in the original warrants were intermingled with records for other athletes not named in those warrants, in light of identical rulings in two other court orders, which the government failed to timely appeal.

Conclusion

The Court of Appeals affirmed in part and reversed in part the lower court's decisions, ultimately ruling that the government must return the unlawfully seized property and that it had acted with callous disregard for the rights of the players.

The revised opinion filed concurrently herewith shall constitute the final action of the court. No petitions for rehearing will be considered.

Who won?

The prevailing party in this case was Comprehensive Drug Testing, Inc. and the players involved in the drug testing program. The courts found that the government had overstepped its bounds by seizing records without proper adherence to the procedures outlined in the warrants. The courts emphasized the importance of protecting the constitutional rights of individuals, particularly in cases involving sensitive information such as drug testing results. The rulings reinforced the principle that the government cannot benefit from its own wrongdoing and must respect the privacy rights of individuals.

The district court did not abuse its discretion by requiring the government to return copies of the seized evidence, as the risk of the players associated with disclosure, and with that the ability of the players' union to obtain voluntary compliance with drug testing from its members in the future, was very high.

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