Department of Labor v. Sturm

CourtDistrict Court, D. New Hampshire
DecidedAugust 4, 1995
DocketCV-94-373-M
StatusPublished

This text of Department of Labor v. Sturm (Department of Labor v. Sturm) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Department of Labor v. Sturm, (D.N.H. 1995).

Opinion

Department of Labor v . Sturm CV-94-373-M 08/04/95 P UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Robert B . Reich, Secretary of Labor, United States Department of Labor, Plaintiff, v. Civil N o . 94-373-M

Sturm, Ruger & Co., Inc., Defendant.

O R D E R

The Secretary of Labor filed suit to enforce an

administrative subpoena served upon Defendant, Sturm, Ruger &

Co., Inc. (the "Company"). The Company operates a firearms

manufacturing plant in New Hampshire. The subpoena directed the

Company to produce records and information related to potential

workplace hazards that might be linked to multiple movement

disorders, like carpal tunnel syndrome. Specifically, the

Secretary sought to obtain the Company's 1993 "OSHA 200 logs" and

first report of injury logs. It also requested information or

records relating t o : (1) employee task completion times;

(2) quotas; (3) piece work; (4) incentives; (5) production;

(6) the Company's ergonomics-related concerns, committees, and

consultants; and (7) employee task variation. The Company is required by law to maintain only the OSHA 200

logs. Nevertheless, the Secretary claims to be entitled to all

of the subpoenaed records and information under the provisions of

the Occupational Safety and Health Act of 1970, 29 U.S.C. §651,

et seq. (the " A c t " ) . The Company objects to enforcement of the

subpoena and moves to vacate an administrative citation and fine

which the Secretary imposed for its refusal to produce the Form

200 logs.

On September 1 , 1994, the Magistrate Judge (Barry, J.)

conducted a hearing on this matter, after which he allowed the

parties 15 days to submit additional legal and factual support

for their respective positions. On March 1 3 , 1995, the

Magistrate Judge issued a Report and Recommendation, recommending

that the court deny the Secretary's application for an order

enforcing the administrative subpoena. The Secretary filed a

timely objection to the Magistrate's Report and Recommendation.

Pursuant to 28 U.S.C. §636(b)(1), the court reviews de novo those

portions of the Report and Recommendation to which a party has

objected.

2 Factual Background.

The Magistrate Judge made the following findings of fact,

which are well-supported in the record. On November 1 , 1992, the

New Hampshire OSHA area director developed a Local Emphasis

Program for the inspection of industries that experience a high incidence of multiple movement disorders, such as carpal tunnel

syndrome and tendinitis. On December 3 1 , 1992, the area director

obtained a computer printout from the New Hampshire Bureau of

Workers' Compensation detailing first reports of injury/illness.

From that data, the area director developed a list of employers

who seemed to be experiencing frequent workers' compensation

claims based on incidents of multiple movement disorder. The

Company had the third highest number of such claims in New

Hampshire.

By letter dated August 1 7 , 1993, the area director advised

the Company of OSHA's general interest in reducing and/or

eliminating ergonomic hazards related to multiple movement

disorders. He also informed the Company of New Hampshire's Local

Emphasis Plan, and its directive to investigate the significant

increase in reports of multiple movement disorders. Finally, he

explained how and why the Company's plant had been selected for

3 inspection. On the same day, OSHA Compliance and Health Officer

Donald DeWees, who was responding to an earlier employee

complaint regarding alleged air quality hazards at the Company's

plant, went to the plant to inspect both air quality and

ergonomics.

DeWees returned to defendant's plant on November 1 2 , 1993,

to inspect the "Checking and Polishing Departments," where

employees had sustained a comparatively large number of multiple

movement disorders. DeWees asked the Company to provide him with

particular information related to that type of injury. On

December 2 0 , 1993, representatives of the Company informed DeWees

that such information would not be released, and instead referred

him to the Company's attorneys. On January 1 1 , 1994, the

Secretary issued the administrative subpoena in question, but the

Company again refused to produce the requested information and

records. On January 1 9 , 1994, the Company's attorney offered, by

way of compromise, to produce the requested records and

information, provided that OSHA agreed not to use any of it as a

basis for an enforcement action against the Company. OSHA

rejected the offer and brought suit to enforce the subpoena.

4 The Company argues that the subpoena violates its rights

under the Fourth Amendment to be free from unreasonable searches

and seizures. The Company claims that the subpoena is

unenforceable because it was not issued "for a proper purpose

authorized by Congress," United States v . Comley, 890 F.2d 539,

541 (1st Cir. 1989). Finally, it challenges the subpoena on

grounds that the Secretary cannot properly subpoena records or

information relating to ergonomics because he has not promulgated

any health and safety regulations on that subject.

Discussion.

I. Constitutional Law.

In Marshall v . Barlow's, Inc., 436 U.S. 307 (1978), the

Supreme Court held that the Fourth Amendment protects commercial

buildings as well as private homes from unreasonable searches and

seizures. The court also concluded that, despite the broad

language of section 8(a) of the Act, the Secretary of Labor could

not conduct a warrantless search of Barlow's business. Barlow's,

436 U.S. at 311. The court noted, however, that demonstrating

"probable cause" sufficient to support the issuance of a warrant

is less burdensome in the administrative inspection context than

in the criminal search context.

5 [The Secretary's] entitlement to inspect will not depend on his demonstrating probable cause to believe that conditions in violation of OSHA exist on the premises. Probable cause in the criminal law sense is not required. For purposes of an administrative search such as this, probable cause justifying the issuance of a warrant may be based not only on specific evidence of an existing violation but also on a showing that "reasonable legislative or administrative standards for conducting an . . . inspection are satisfied with respect to a particular [establishment]."

Barlow's, 436 U.S. at 320 (quoting Camara v . Municipal Court of

San Francisco, 387 U.S. 523, 538 (1967)); see also Brock v .

Brooks Woolen Co., 782 F.2d 1066, 1069 (1st Cir. 1986) ("In the

case of an administrative search warrant, . . . the probable

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