Martinique Stoudemire v. Mich. Dep't of Corrections, 2013 U.S. App. LEXIS 2159

Stoudemire, a double amputee and former inmate at Huron Valley, sues MDOC and several MDOC personnel under §1983, the ADA, and Mich. Comp. Laws § 330.1722, alleging inadequate medical care and abusive confinement following her final amputation.
She suffered from systemic lupus erythematosus, hypercoagulopathy, depression, and related health risks, with subsequent heart/liver issues and multiple surgeries while incarcerated.
After December 2006, her stump and buttock were infected with MRSA and she was quarantined in Huron’s segregation unit, which allegedly had no accommodations for disabled inmates.
Davis, the warden who designated segregation as the quarantine site, is alleged to bear responsibility for Stoudemire’s confinement conditions; Davis testified she was aware of the quarantine designation but not specifics.
Stoudemire challenges a 2007 strip search by Officer Dunagan, asserting humiliating, visible search conditions; Dunagan counters with a different sequence of events, and notes a reprimand for improper procedure, with missing contraband-removal records.
The district court denied summary judgment on qualified immunity for both Davis and Dunagan; the court did not resolve the state-law immunity defenses, prompting this interlocutory appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Davis’s qualified immunity is warranted for the Eighth Amendment confinement claim	Stoudemire argues Davis violated clearly established rights by denying adequate medical accommodation	Davis contends no clearly established right was violated given the circumstances	Vacate denial as to Davis and remand for proper individualized analysis
Whether Dunagan is entitled to qualified immunity for the strip-search claim	Stoudemire asserts the search was unreasonable and not justified by penological interests	Dunagan argues the search could be reasonable under Turner/related standards	Affirm the denial of summary judgment on Dunagan’s qualified immunity
Whether state-law governmental immunity defenses should be addressed on remand	State-law defenses should be considered	Defendants seek dismissal under state immunity rules	Remand to district court to address state-law immunity defenses

Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (deliberate indifference standard for jail medical care)
Anderson v. Creighton, 483 U.S. 635 (U.S. 1987) (clearly established right requires a reasonable official to know of illegality)
Saucier v. Katz, 533 U.S. 194 (U.S. 2001) (two-step qualified immunity framework (original))
Pearson v. Callahan, 555 U.S. 223 (U.S. 2009) (modifies to allow discussion of prongs in any order)
Bell v. Wolfish, 441 U.S. 520 (U.S. 1979) (test for reasonableness of searches in prison context; factors)
Florence v. Bd. of Chosen Freeholders of Burlington Cnty., 132 S. Ct. 1510 (S. Ct. 2012) (test balancing need against invasion in prison strip searches)
Hudson v. Palmer, 468 U.S. 517 (U.S. 1984) (no general privacy expectation in cells, but bodily privacy rights apply)
Cornwell v. Dahlberg, 963 F.2d 912 (6th Cir. 1992) (prison privacy expectations in general)
Michenfelder v. Sumner, 860 F.2d 328 (9th Cir. 1988) (privacy and penological interests in strip searches)
Garr et al. v. City of Madison Heights, 407 F.3d 789 (6th Cir. 2005) (per-officer individualized inquiry for qualified immunity)
Turner v. Safley, 482 U.S. 78 (U.S. 1987) (deference to prison regulations must be balanced against rights)
Dickerson v. McClellan, 101 F.3d 1151 (6th Cir. 1996) (jurisdiction over purely legal questions in qualified immunity)