Allison v. Muhlenberg County Detention Center
4:18-cv-00037
| W.D. Ky. | Apr 23, 2018Background
- Plaintiff Henry Pete Allison III, a jail inmate at Muhlenberg County Detention Center (MCDC), filed a pro se § 1983 complaint proceeding in forma pauperis.
- Allegation: on January 4, 2018, Deputy Jailer Seth Blakeley strip-searched Allison in another inmate’s isolation cell while recording the search on video; a designated strip-search room without cameras exists but was not used for Allison.
- Plaintiff seeks relief for invasion of privacy and humiliation caused by the search and video recording.
- The Court screened the complaint under 28 U.S.C. § 1915A and applicable pleading standards for pro se inmates.
- The Court treated the claim as a Fourth/Eighth Amendment challenge to the strip search and considered controlling § 1983 requirements (constitutional violation by state actor).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a strip search recorded on video violated constitutional rights | Allison: being strip-searched on camera in another cell violated his privacy and caused humiliation | Defendants: presence of a camera or other inmates/employees does not, without more, make a search unconstitutional | Court: Dismissed — allegation of a strip search on video, without additional facts, does not state a constitutional violation |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading must state a plausible claim)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility standard for complaints)
- West v. Atkins, 487 U.S. 42 (§ 1983 requires constitutional violation by state actor)
- Gomez v. Toledo, 446 U.S. 635 (elements of a § 1983 claim)
- Haines v. Kerner, 404 U.S. 519 (pro se complaints held to less stringent standard)