Hair testing, cocaine, corrections, policy and procedure, evidence, search.

Anthony Medina, a probationer with the New York Department of Corrections, challenges the admission of hair testing results as evidence in a hearing concerning his probation status. Medina was convicted of a narcotics violation and assigned probation. He agreed to remain drug free while on probation. Medina tested positive for cocaine during his probation period and was placed in a treatment program. During a hearing on another probation violation, Medina was ordered to submit a sample of hair for drug analysis. Authorities decided to use radio immunoassay (RIA) hair testing procedures instead of a urine sample because the exam can detect traces of drugs that have been absorbed in the blood stream. A positive result indicates past drug use. Medina's hair sample tested positive for cocaine and authorities moved to revoke his probation.

This is the first judicial review of this case.

Medina loses. The U.S. District Court for the Eastern District of New York ruled that the procedures used in radio immunoassay hair testing produced accurate and reliable results. Therefore, Medina's positive results in the drug test could be admitted as evidence that he violated the terms of his probation.