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Anderson, Keith, Michetti, Rita, McCarron Stephen J., Naimoli, Robert R., Plower, Charles, Rascento, Frank and Turley, Lasonya D. On Behalf of Themselves and All Others Similarly Situated v. The City of Philadelphia, Philadelphia Police Commissioner Tucker, Kevin and Superintendent of Prisons Owens, David, Jr., Both in Their Individual and Official Capacities and the Commonwealth of Pennsylvania. Appeal of City of Philadelphia, Philadelphia Police Commissioner Kevin Tucker, and Superintendent of Prisons David Owens, Jr

Citation: 845 F.2d 1216Docket: 87-1546

Court: Court of Appeals for the Third Circuit; May 31, 1988; Federal Appellate Court

Narrative Opinion Summary

The case concerns an appeal by the City of Philadelphia and its police and prison departments against a district court ruling that polygraph testing for pre-employment screening violated the plaintiffs' constitutional rights. The appellate court reversed the decision, concluding that the polygraph requirement does not infringe upon due process or equal protection rights. The plaintiffs, unsuccessful job applicants, claimed deprivation of property and liberty interests; however, the court found no legitimate entitlement to employment. Under Pennsylvania law, polygraph testing is generally prohibited but exempt for law enforcement agencies. The court applied a rational basis review, determining the polygraph's use as rationally related to hiring qualified officers. Confidentiality of test results negated any liberty interest claims. The court supported the departments' discretion in employing polygraphs despite ongoing debates over their validity, citing no superior alternatives. Thus, the appellate court ruled in favor of the defendants, asserting the constitutional permissibility of polygraph use in law enforcement hiring processes.

Legal Issues Addressed

Confidentiality and Liberty Interests

Application: The claim of deprivation of a liberty interest was rejected as the plaintiffs did not allege public dissemination of stigmatizing information.

Reasoning: However, since they did not allege that the results were made public, and the confidentiality of such results was unchallenged, their claim of deprivation of a liberty interest is deemed untenable.

Due Process and Equal Protection in Employment Screening

Application: The appellate court determined that the use of polygraph testing in employment screening by law enforcement agencies does not infringe on the plaintiffs' due process and equal protection rights.

Reasoning: The appellate court disagreed, determining that the polygraph requirement does not infringe upon constitutional rights.

Exemptions under Pennsylvania Law for Polygraph Testing

Application: Law enforcement agencies are exempt from the general prohibition on polygraph testing for employment under Pennsylvania law.

Reasoning: According to Pennsylvania law, the use of polygraph tests for employment screening is generally prohibited, with exceptions for public law enforcement agencies.

Legislative Discretion in Employment Screening Methods

Application: The court upheld the use of polygraph testing in employment screening by law enforcement as a permissible exercise of legislative discretion despite the absence of scientific consensus on its validity.

Reasoning: In the absence of scientific consensus, law enforcement administrators can legally implement a polygraph requirement in hiring processes without violating the equal protection clause.

Property and Liberty Interests in Procedural Due Process

Application: The court found that the plaintiffs lacked a protected property or liberty interest necessary for a procedural due process claim as they were merely job applicants.

Reasoning: The plaintiffs must show that Pennsylvania law conferred them a legitimate entitlement to employment as police or prison officers. However, they were merely applicants and held no more than a right to be considered for employment based on their positions on the civil service eligibility list.

Rational Basis Review in Equal Protection Claims

Application: The court applied rational basis review and concluded that the polygraph testing requirement is rationally related to the legitimate interest of hiring qualified law enforcement officers.

Reasoning: The plaintiffs' equal protection claim is evaluated under the rational basis standard, which presumes legislative validity if classifications are rationally related to legitimate state interests.