Adrian King, Jr. v. Jim Rubenstein
2016 U.S. App. LEXIS 10276
| 4th Cir. | 2016Background
- Adrian F. King Jr., an incarcerated inmate at Huttonsville Correctional Center, had pre-incarceration penile "marble" implants and tattoos; staff discovered the implants and charged him under a policy banning tattooing/piercing and exposure of body fluids.
- After disciplinary findings, King was placed in segregation and alleges he was coerced—by threats of continued segregation and loss of parole eligibility—into consenting to surgical removal of the implants at a hospital.
- Medical staff had previously determined the implants were not recently inserted and presented no sign of infection; King alleges the surgery caused physical pain, scarring, numbness, and emotional injury.
- King sued under 42 U.S.C. § 1983 against multiple prison officials asserting Fourth Amendment (unreasonable search/seizure), Eighth Amendment (cruel and unusual punishment), and Fourteenth Amendment (equal protection and due process) claims; some defendants were dismissed by the district court.
- The Fourth Circuit reviewed the 12(b)(6) dismissal de novo, accepting King’s factual allegations and inferences and considering attachments integral to the complaint.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Fourth Amendment - bodily search (surgery) | King contends the compelled surgery was an unreasonable, sexually invasive bodily search done under coercion and caused injury | Defendants argue Hudson limits prisoners’ privacy and contend security/contraband concerns justified removal; also that King consented | Reversed: Wolfish factors show intrusion scope, manner, and lack of penological justification render the surgery plausibly unreasonable at pleading stage |
| Eighth Amendment - cruel and unusual punishment | King argues coercion into surgery via segregation threats caused serious physical and psychological harm and was motivated by harassment | Defendants contend segregation and corrective action were legitimate and not an Eighth Amendment violation | Reversed: Allegations satisfy serious-deprivation and deliberate-indifference components plausibly supporting an Eighth Amendment claim |
| Fourteenth Amendment Equal Protection (class-of-one) | King alleges he was singled out for forced surgery while other inmates with implants were allowed to keep them | Defendants assert the actions were rationally related to legitimate penological interests (security/health) | Reversed: Allegations that similarly situated inmates were treated differently and lack of rational penological justification survive dismissal |
| Fourteenth Amendment Due Process (refusal of medical treatment) | King asserts a liberty interest in refusing unwanted medical treatment and that coerced surgery violated substantive due process | Defendants argue issue not properly raised and that penological interests can justify treatment in prison | Remanded: Court finds King pleaded facts sufficient to raise a due-process claim and directs the district court to consider it |
Key Cases Cited
- Hudson v. Palmer, 468 U.S. 517 (1984) (prisoners have diminished privacy but constitutional limits remain)
- Bell v. Wolfish, 441 U.S. 520 (1979) (framework for reasonableness of invasive searches of detainees/prisoners)
- Schmerber v. California, 384 U.S. 757 (1966) (analysis of bodily intrusions and risk/trauma considerations)
- Winston v. Lee, 470 U.S. 753 (1985) (limitations on compelled surgery where risks and intrusion outweigh justification)
- Cruzan v. Director, Missouri Dept. of Health, 497 U.S. 261 (1990) (competent person’s liberty interest in refusing unwanted medical treatment)
- Turner v. Safley, 482 U.S. 78 (1987) (standard for assessing prison regulations impinging on inmates’ rights)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard for prison official liability)
- Rhodes v. Chapman, 452 U.S. 337 (1981) (Eighth Amendment prohibits punishments totally without penological justification)