Amanda Sumpter v. Wayne Cty.
868 F.3d 473
6th Cir.2017Background
- Amanda Sumpter was detained at Wayne County Jail Oct–Nov 2012 and underwent four strip searches: three in the Registry (intake) conducted by Corporal Terri Graham with other female inmates present, and one in her cellblock after a cell search.
- Registry searches: Graham escorted groups of up to five women into a room, had them disrobe and perform visual checks (squat/cough, lift breasts, etc.); other inmates could observe; Graham made rude comments about Sumpter’s hygiene.
- Cellblock search: after cell searches, inmates were lined up and ordered to disrobe in the common area; Sumpter testified she saw/heard male silhouettes in the duty “Bubble” who appeared to be watching.
- Sumpter sued Graham (individual), Wayne County, and the Sheriff (official capacity) under 42 U.S.C. § 1983 alleging Fourth Amendment violations; she sought monetary, declaratory, and injunctive relief and class certification.
- District court granted summary judgment to Graham (qualified immunity), to the County and Sheriff on Monell claims (no policy/custom shown), and dismissed injunctive/declaratory claims for lack of a live controversy; Sixth Circuit majority affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Graham violated Sumpter’s Fourth Amendment rights by conducting group strip searches in the Registry | Sumpter: group searches were humiliating and conducted in front of others without adequate justification | Graham: searches were limited, done only when intake volume made individual searches imprudent to avoid dangerous delays and to expedite medical/mental-health routing | Court: did not decide Fourth Amendment violation on merits for qualified-immunity analysis; assumed intrusion but found no clearly established law putting Graham on notice; qualified immunity affirmed |
| Whether prior Sixth Circuit precedent clearly established that group strip searches under these circumstances are unlawful (qualified-immunity question) | Sumpter: Stoudemire and Williams established right not to be publicly strip-searched absent legitimate penological justification | Graham: earlier cases were distinguishable (they lacked any penological justification) and post‑date the events; no precedent ‘‘squarely governs’’ group searches justified by intake exigencies | Court: rights were not sufficiently particularized; Stoudemire/Williams didn’t clearly establish unlawfulness here; Graham entitled to qualified immunity |
| Whether Wayne County is liable under Monell for the cellblock search in front of male officers (policy/custom) | Sumpter: affidavits from many inmates show a pattern/custom of group/public searches and exposure to male officers | County: plaintiff presented only a single incident tied to the cellblock and failed to present or properly present affidavits to the district court on that claim | Court: plaintiff failed to identify and rely on affidavits re: the cellblock claim in district court; single-incident theory insufficient to establish municipal policy/custom; summary judgment for County affirmed |
| Whether Sumpter had standing for injunctive/declaratory relief (live controversy) | Sumpter: her experience and class claims justify equitable relief; exceptions for class actions or ‘‘capable of repetition yet evading review’’ apply | Defendants: Sumpter was no longer detained and the jail revised its policy to prohibit group strip searches, so no reasonable likelihood she will be subjected again | Court: named-plaintiff lacked a present, concrete, imminent injury to pursue injunctive/declaratory relief; standing absent, so those claims fail (court treats as standing issue rather than mootness) |
Key Cases Cited
- Florence v. Board of Chosen Freeholders of County of Burlington, 566 U.S. 318 (2012) (deference to correctional officials; blanket intake strip searches permissible given institutional burdens)
- Bell v. Wolfish, 441 U.S. 520 (1979) (Fourth Amendment reasonableness in corrections: balance intrusion against penological need; courts must defer absent substantial evidence of exaggerated response)
- Stoudemire v. Michigan Department of Corrections, 705 F.3d 560 (6th Cir. 2013) (public strip search found unreasonable where no time/resource exigency justified exposing detainee)
- Williams v. City of Cleveland, 771 F.3d 945 (6th Cir. 2014) (plausible Fourth Amendment claim where detainees allegedly forced to undress and subjected to invasive delousing in presence of others; less-intrusive alternatives alleged)
- Saucier v. Katz, 533 U.S. 194 (2001) (qualified immunity two-step framework; need for particularized clearly established law)
- Pearson v. Callahan, 555 U.S. 223 (2009) (courts may decide qualified-immunity prongs in either order)
- Brosseau v. Haugen, 543 U.S. 194 (2004) (circuit precedent must be factually similar to clearly establish right)
- Plumhoff v. Rickard, 572 U.S. 765 (2014) (clearly established standard requires that a reasonable official would understand conduct violated law)