Monday v. Oullette, 118 F.3d 1099, 1104-05 (6th Cir.1997); Ludwig v. Anderson, 54 F.3d 465, 471 (8th Cir.1995); Fernandez v. City of Cooper City, 207 F.Supp.2d 1371, 1380 (S.D.Fla.2002); Gainor v. Douglas Cnty., 59 F.Supp.2d 1259, 1287-88 (N.D.Ga.1998); Griffin v. City of Clanton, 932 F.Supp. 1359, 1369 (M.D.Ala.1996). 39 . Although Fils involved a taser, not chemical spray, the court found "no meaningful distinction between the two under the [present] circumstances.” 647 F.3d at 1289 (comparing Draper v. Reynolds, 369 F.3d 1270, 1278 (11th Cir.2004) (stating that, while a taser shock is "unpleasant,” it “did not inflict any serious injury” on the plaintiff) with Vinyard, 311 F.3d at 1348 (describing pepper spray as "generally of limited intrusiveness)). 40 . More specif 5 S.Ct. 2386 (<HOLDING>); Hazel-wood Sch. Dist. v. Kuhlmeier, 484 U.S.
holding railroad regulation requiring random drug testing without particularized suspicion to be reasonable in light of connection to public safety holding that random drug testing for student athletes did not violate their fourth amendment rights holding that consensual random drug testing of students participating in extracurricular activities were searches under the fourth amendment even though they were not part of a criminal investigation and a positive test resulted only in suspension from participation holding that a us department of labor drug testing plan did not on its face violate the fourth amendment but emphasizing that the ruling did not preclude an as applied constitutional challenge holding that search of middle school student violated her fourth amendment rights