Reasonable suspicion, random testing, corrections, due process, chain of custody, Fourth Amendment, Fifth Amendment, Sixth Amendment, Fourteenth Amendment,

Randall Wykoff, a former prisoner at the Westville Work Release Center, filed suit against facility employees and the Indiana Department of Corrections, after officials revised the terms of his sentence. Wykoff tested positive for drugs twice in a four month period in the department's random testing program for inmates. Corrections officials revised his sentencing terms, based on the test results. Wykoff later filed suit, claiming department officials violated constitutionally protected rights. Wykoff challenged both the drug test results and the methods in which the samples were handled.

State officials rejected Wykoff's efforts to appeal his revised sentence through the department's appeal process.

Wykoff loses. The U.S. District Court for the Northern District of Indiana upheld the department's decision to revise Wykoff's sentence. The court ruled the testing procedures did not violate Wykoff's rights. The court also ruled that that chain of custody procedures were adequate, but the court stated the department should consider revising its testing methodology.