John Arnzen, III v. Charles Palmer, 713 F.3d 369

CCUSO houses civilly and involuntarily committed individuals deemed sexually violent predators.
Cameras were placed in all bathrooms, including single-user restrooms (some with doors, some with T-junctions).
Single-user restrooms can be accessed by multiple patients at once; some doors can be locked from the outside or from inside in limited areas.
Cameras in common areas are monitored; cameras in restrooms record and are not monitored in real time, with footage erased after 14–21 days and masked unless unmasked for investigations.
District court granted injunctions: cameras in dormitory-style restrooms allowed; cameras in traditional single-user bathrooms required ceiling/ lens-cap treatment; CCUSO appealed, and the court affirms.
Court engages in Fourth Amendment analysis and preliminary-injunction factors to determine reasonableness of the searches and the balance of harms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether CCUSO cameras in single-user bathrooms constitute a Fourth Amendment search	Plaintiffs allege fear of privacy invasion in single-user bathrooms.	Administrators claim cameras prevent harm and are necessary for security.	Yes, it is a search under the Fourth Amendment.
Whether the district court abused its discretion in issuing a preliminary injunction	Injunction necessary to protect privacy; harms outweigh public interest.	Cameras necessary for safety; district court gave deference to professionals.	No abuse of discretion; injunction affirmed.
Whether less intrusive alternatives existed to achieve safety without invasive cameras	Less intrusive measures available, e.g., interior door locking and monitoring protocols.	Cameras are uniquely effective for safety.	There are less intrusive methods; district court did not err in finding alternatives.
Whether public interest favors Fourth Amendment protections over institutional security during injunction	Privacy rights outweigh interests in safety.	Public safety and order justify camera use.	Public interest favoring privacy and dignity outweighed.

Kyllo v. United States, 533 U.S. 27 (Supreme Court 2001) (defined a search as government intrusion on reasonable privacy expectations)
Beaulieu v. Ludeman, 690 F.3d 1017 (8th Cir. 2012) (requires deference to correctional officials unless evidence shows unnecessary policies)
Serna v. Goodno, 567 F.3d 944 (8th Cir. 2009) (balancing test for searches; less-intrusive alternatives considered)
Bell v. Wolfish, 441 U.S. 520 (Supreme Court 1979) (detainees’ privacy expectations are diminished; cell searches analogies used)
Serna v. Goodno (quoted for balancing principles), 567 F.3d 944 (8th Cir. 2009) (emphasizes scope and justification factors in institutional settings)
Youngberg v. Romeo, 457 U.S. 307 (Supreme Court 1982) (deference to professional judgments in custodial settings)