The 9th Circuit Court of Appeals recently ruled in a 2-1 decision that the federal government could obtain the test results of about 100 baseball players that tested positive for steroids in 2003.  This was the year of experimental testing, whereby the players would be tested anonymously, but there would be no individual repercussions for positive tests.  The only reason for the tests was to determine the extent of the steroid use in baseball.  If 5% or more of the tests came back positive, then testing would continue.  It looks like there were 100 or so positive test for about 1200 players (30 teams X 40 players) for about a 8% positive rate.

However, according to The Sports Law Blog, the ruling has far greater implications:  

Simply, by allowing investigators to use the initial warrant as a basis for gathering gobbs of incriminating information with respect to non-targeted individuals, the investigators, in effect, were able to use a generalized search warrant to obtain evidence without probable cause. The court used the difficulty of retrieving and separating electronic data as an excuse to allow federal investigators full discretion to not only retrieve private and confidential information about thousands of individuals that are not even the subject of the warrant and for which there is no probable cause, but to also determine when there is "intermingling" such that an on-site search would be impracticable. This puts way too much discretion in the hands of federal investigators. Even further, the court didn't place any limitations on the government's use of incriminating evidence obtained with respect to non-targeted individuals.

This strikes me as the best analysis of the further implications of this ruling that I've read.  The MLBPA has said they will appeal the ruling.

Now, I want baseball to clean up the game and I'm as curious as anyone who those 100 players are.  However, does it really matter if any of those 100 were on the 2003 Phillies team or if any of them are playing for the Phillies now?  The drug testing now results in stiff public penalties.  I'm satisfied that MLB is making a good effort to test for detectable performance enhancing drugs.

The MLBPA has three recourses: 1) appeal to the same 3 judge panel, 2) appeal to the entire 9th Circuit for a rehearing, en banc or 3) appeal to the US Supreme Court.

I don't think an appeal before the same 3 judges will change anything nor do I think the US Supreme Court will hear this case at this time, so option 2 seems like the best bet.  I also predict that the very liberal 9th Circuit will not allow the federal government this much subpoena power and they'll reverse this decision.