Eaton v. Lexington-Fayette Urban County Government, 811 F.3d 819

Eaton challenged a municipal drug-testing program as applied to a family-court custody context.
The program required urine testing under court order; Eaton repeatedly tested with positive results.
He sought federal relief under §1983 for Fourth Amendment violations and damages.
The district court dismissed claims for declaratory and injunctive relief and stayed damages claims, then granted summary judgment on the merits.
On review, the court affirmed the district court’s ruling that Eaton failed to show a genuine factual dispute and that the program was reasonable under Fourth Amendment standards.
The court emphasized the program’s court-ordered basis, trained personnel, procedures, and the use of a reliable testing method.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the program’s testing is reasonable under the Fourth Amendment.	Eaton argues reliability flaws render tests unconstitutional.	Lexington shows strong governmental interest and valid procedures.	Yes; program reasonable and summary judgment proper.
Whether Eaton’s evidentiary challenges create a triable issue of fact.	Eaton asserts unreliable procedures and seeks jury evaluation of evidence.	No evidence in record shows inaccuracies; no triable fact exists.	No; Eaton failed to proffer probative evidence to defeat summary judgment.

Vernonia School District 47J v. Acton, 515 U.S. 646 (U.S. 1995) (testing as a search; reasonableness depends on fact-specific balancing)
Brigham City v. Stuart, 547 U.S. 398 (U.S. 2006) (reasonableness with intrusive searches in emergencies)
Bd. of Educ. v. Earls, 536 U.S. 822 (U.S. 2002) (school drug testing as reasonable under balancing test)
Skinner v. Ry. Labor Executives’ Ass’n, 489 U.S. 602 (U.S. 1989) (accuracy as a factor in reasonableness of testing regime)
National Treasury Employees Union v. Von Raab, 489 U.S. 656 (U.S. 1989) (recognizes intrusiveness balancing in drug testing)