Baughman v. Wal-Mart Stores, Inc.

592 S.E.2d 824, 215 W. Va. 45, 20 I.E.R. Cas. (BNA) 1199, 2003 W. Va. LEXIS 154
CourtWest Virginia Supreme Court
DecidedDecember 4, 2003
Docket31312
StatusPublished
Cited by3 cases

This text of 592 S.E.2d 824 (Baughman v. Wal-Mart Stores, Inc.) is published on Counsel Stack Legal Research, covering West Virginia Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Baughman v. Wal-Mart Stores, Inc., 592 S.E.2d 824, 215 W. Va. 45, 20 I.E.R. Cas. (BNA) 1199, 2003 W. Va. LEXIS 154 (W. Va. 2003).

Opinion

*47 PER CURIAM:

In the instant ease, we uphold a grant of summary judgment by a circuit court in a ease alleging invasion of privacy.

I.

In the instant case, the appellant, Stephanie Baughman, filed suit on July 5, 2001, against the appellee Wal-Mart Stores, Inc., in the Circuit Court of Harrison County. The appellant’s complaint stated that the appellant was required to give a urine sample prior to her employment by a Wal-Mart store. That is, the appellant was offered a job by Wal-Mart — but prior to the appellant’s starting work, Wal-Mart required her (and allegedly all other prospective employees) to first give a urine sample that Wal-Mart would test for results that may indicate illegal drug use. The appellant gave the urine sample and thereafter began working at Wal-Mart; she later left her employment at Wal-Mart for reasons apparently unrelated to the instant ease.

The appellant’s complaint stated that Wal-Mart’s pre-employment requirement of giving a urine sample for drug testing after being offered a job, but before starting to work, was per se an actionable invasion of the appellant’s privacy; and that Wal-Mart had, by requiring the sample, caused the appellant “embarrassment, indignity, humiliation, annoyance, inconvenience and other general damages.” 1

Wal-Mart filed an answer admitting that the appellant had been required to submit a urine sample for drug testing, but denying that there was any illegality in or harm from this requirement. Thereafter, some limited amount of discovery took place. The appellant then filed a motion for partial summary judgment on the issue of liability. Wal-Mart filed a cross-motion for summary judgment on the same issue. The circuit court granted summary judgment to Wal-Mart, holding that the appellant had not shown an actionable invasion of privacy in Wal-Mart’s requiring her to submit a urine sample for drug testing before she began to work for Wal-Mart. 2

II.

We review a grant of summary judgment de novo.

The appellant’s principal argument is based on our holding in Twigg v. Hercules Corp., 185 W.Va. 155, 406 S.E.2d 52 (1990). In Twigg, this Court stated in Syllabus Points 1 and 2:

1. It is contrary to public policy in West Virginia for an employer to require an employee to submit to drug testing since such test portends an invasion of an individual’s right to privacy.
2. Drug testing will not be found to be violative of public policy grounded in the potential intrusion of a person’s right to privacy where it is conducted by an employer based upon reasonable good faith objective suspicion of an employee’s drug usage or while an employee’s job responsibility involves public safety or the safety of others, [emphasis added].

*48 Notably, and for the purposes of our holding in the instant ease, importantly, Twigg was a case involving the issues arising from an employer’s requirement of drug testing by current, existing employees — not by prospective employees who had not begun employment.

Our decision in Twigg relied upon Roach v. Harper, 143 W.Va. 869, 105 S.E.2d 564 (1958), in which we held in Syllabus Point 1 that:

1. The right of privacy, including the right of an individual to be let alone and to keep secret his private communications, conversations and affairs, is a right the unwarranted invasion or violation of which gives rise to a common-law right of action for damages.
In Roach, we stated:
The “right of privacy” has been defined as the right of an individual to be let alone, to live a life of seclusion, or to be free from unwarranted publicity. The right of privacy is closely related to many other subjects of law, e. g., libel and slander, literary property, wrongful search and seizure, compulsory physical examination and eavesdropping. Though different in some respects from such subjects, the right to privacy is an individual right that should be held inviolate. To hold otherwise, under modern means of communication, hearing devices, photography, and other technological advancements, would effectively deny valuable rights and freedoms to the individual.
The usual argument against the existence of the right of action is that it is for a wrong or tort for which no recovery was permitted at common law. We need not here, however, theorize as to the basis for the existence of the right. As above pointed out, that existence has been affirmed by the very great weight of authority. It may not be amiss, however, to quote language of Judge Parker in the opinion in Barnes Coal Corporation v. Retail Coal Merchants Ass’n, 4 Cir., 128 F.2d 645, 648: “ * * * It must be remembered, in this connection, that the common law is not a static but a dynamic and growing thing. Its rules arise from the application of reason to the changing conditions of society. It inheres in the life of society, not in the decisions interpreting that life; and, while decisions are looked to as evidence of the rules, they are not to be construed as limitations upon the growth of the law but as landmarks evidencing its development. As was said in Hurtado v. [People of State of California, 110 U.S. 516, 530, 4 S.Ct. [111], 118, 28 L.Ed. 232, “Flexibility and capacity for growth and adaptation is the peculiar boast and excellence of the common law” * * [citations omitted].

143 W.Va. at 876-877,105 S.E.2d at 568. See also Syllabus Point 3, Sutherland v. Kroger Co., 144 W. Va. 673, 110 S.E.2d 716 (1959) (“An illegal search by a private individual is a trespass in violation of the right of privacy.”); Cordle v. General Hugh Mercer Corp., 174 W.Va. 321, 325 S.E.2d 111 (1984) (imposing polygraph requirement on employees is contrary to public policy).

The appellant argues that this Court should overrule the circuit court’s order granting summary judgment by extending the principles set forth in Twigg to apply categorically to all instances of employment-related drug testing — both during employment, and pre-employment.

The appellee responds by arguing that the balancing between an individual’s right of privacy and the needs and rights of a private employer is substantially different in the pre-employment context, and that therefore the holding in Twigg is both inapposite and inapplicable to the instant case.

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592 S.E.2d 824, 215 W. Va. 45, 20 I.E.R. Cas. (BNA) 1199, 2003 W. Va. LEXIS 154, Counsel Stack Legal Research, https://law.counselstack.com/opinion/baughman-v-wal-mart-stores-inc-wva-2003.