Steele-Warrick v. Microgenics Corporation — 2d Cir. (Oct 20, 2026)
The Second Circuit hears four consolidated appeals over New York's prison drug-testing program. In 2019, prisoners were disciplined after urine samples tested positive using Microgenics equipment. The prisoners say false results led to cell confinement, lost privileges, and delayed release. A state investigation found that positive screening results were being checked by repeating the same test, rather than confirmed through a more specific method. The prisoners sued the testing companies and state officials, accusing officials of ignoring mounting warnings that the tests were unreliable. The officials say they reasonably relied on the vendor and investigated the complaints before stopping tests and reversing discipline. These appeals focus on the officials' request for qualified immunity. That protection shields officials from damages when existing law did not give fair warning that their conduct was unlawful. They will argue that no sufficiently similar precedent put them on notice here. The prisoners' lawyer will argue that allowing arbitrary punishment can violate substantive due process, and that disputes over who knew what require a trial. Procedural due process concerns the hearings and safeguards required before punishment; substantive due process limits certain arbitrary government conduct itself. The judges will question both whether a protected liberty interest is at stake and whether these officials' conduct could meet the demanding standard of shocking the conscience.
Steele-Warrick v. Microgenics Corporation (No. 26-409) — U.S. Court of Appeals for the Second Circuit, argued October 20, 2026.
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