In the US Supreme Court case Samuel K. Skinner v. Railway Labor Executives Association (489 U.S. 602), the Court held that both blood and urine tests were minimally intrusive. While the Court acknowledged that the act of passing urine was in itself intensely personal, obtaining a urine sample in a medical environment and without the use of direct observation amounted to no more than a minimal intrusion. The Court justified not only testing of urine but also testing of blood by focusing on the procedure of testing (i.e., "experience . . . teaches that the quantity of blood extracted is minimal,” and pointing out that since such tests are "common place and routine in everyday life," the tests posed "virtually no risk, trauma, or pain".. While such testing does amount to an imposition upon an employee (i.e., by requiring her to report to a physician and provide a urine sample) in a way that may not be commonplace for many employees, the Court ruled that since this takes place within an employment context (where limitations of movement are assumed), this interference is justifiable and does not unnecessarily infringe on privacy interests.
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