Reasonable suspicion, evidence, marijuana, disparate treatment, safety, policy and procedure, discrimination

Willie Chaney, a former security officer with the Southern Railway Company, appeals a lower court's ruling in a discrimination suit. Company officials ordered Chaney to complete a drug test after a supervisor reported a marijuana-like odor on Chaney. The test posted positive for the drug and the railway terminated Chaney's employment. Chaney subsequently filed suit, claiming the urine test used in his case frequently reports false-positive results in test samples provided by African Americans. The company responded to Chaney's discrimination suit with a motion for summary judgment.

A district court granted the company's motion for summary judgment. Chaney now appeals.

A split decision. The U.S. Court of Appeals for the Eleventh Circuit affirmed in part and reversed in part. The appeals court affirmed the lower court's ruling concerning Chaney's disparate treatment complaint. However, the appeals court remanded the case for trial on Chaney's disparate "impact" complaint.