“It is undisputed that urinalysis testing is a search under the Fourth Amendment and that drug testing in the prison context is generally constitutional unless it is conducted in an unreasonable manner. See Thompson v. Souza, 111 F.3d 694, 701 (9th Cir. 1997). The reasonableness of prison drug testing ‘requires “[b]alancing the significant and legitimate security interests of the institution against the privacy interests of the inmates.”’ Id. at 702.” Riley v. Kernan, 2020 U.S. App. LEXIS 21159 (9th Cir. July 8, 2020).
Whether a subpoena is unlawful or not might bear on its disclosure questions. The government is directed to address that in a brief. In re Grand Jury Subpoena, 2020 U.S. Dist. LEXIS 119134 (E.D. N.Y. June 19, 2020).*