May v. Trancoso, 412 F. App'x 899

May, an inmate, sues under 42 U.S.C. § 1983 alleging Eighth Amendment violations from a second strip search, a degrading drug test, retaliation, and ignored shoulder injury.
During a June 2004 non-emergency drill, May was strip searched in his cell in front of a female officer, then later in a common area under observation.
The second search involved several female civilian spectators and multiple female staff, with jeering comments and nudity-focused behavior.
May remained handcuffed for three hours, complained of shoulder pain, was ignored while needing to urinate, and found personal items missing or broken after return to his cell.
The district court granted summary judgment on most claims, except for the second strip search claim, and later dismissed the shoulder-injury claim as not showing serious medical need.
May exhausted administrative remedies by appealing the grievances to the Board and the director.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the second strip search conducted to humiliate May in violation of the Eighth Amendment?	May argues the presence of civilian spectators and jeering shows intent to humiliate.	Defendants contend the search had a penological justification and no evidence of intent to humiliate.	Triable issue exists; vacate and remand on this claim.
Did May’s protest during the second search support a retaliation claim?	May asserts protests were protected activity and the more invasive search was retaliation.	Searchs were not meaningfully more invasive than others; no causal link shown.	Summary judgment affirmed; retaliation claim rejected.
Did the urine drug test violate constitutional protections?	Test was degrading and humiliating beyond penological necessity.	Private, monitored test with minimal spectators has legitimate penological justification.	No constitutional violation; test permissible.
Did Goken act with deliberate indifference to May’s shoulder injury?	Cuffing behind the back and delay in addressing pain worsened the injury.	Guards are not required to accept inmate reports as true; no evidence of known serious medical need.	District court's dismissal affirmed; no deliberate indifference shown.
Was May required to exhaust administrative remedies for all claims?	Administrative avenues were pursued through the Board and director.	Exhaustion not shown for all claims.	Exhaustion shown; properly treated.

Mays v. Springborn, 575 F.3d 643 (7th Cir. 2009) (strip-search humiliation standard for Eighth Amendment questions)
Whitman v. Nesic, 368 F.3d 931 (7th Cir. 2004) (considerations for humiliating conduct in prisoner searches)
Calhoun v. DeTella, 319 F.3d 936 (7th Cir. 2003) (presence of witnesses and ridicule as indicators of intent)
Peckham v. Wis. Dep’t of Corr., 141 F.3d 694 (7th Cir. 1998) (veteran framework for analyzing Eighth Amendment strip-search claims)
Johnson v. Phelan, 69 F.3d 144 (7th Cir. 1995) (cross-sex monitoring and penological justification considerations)
Farmer v. Perrill, 288 F.3d 1254 (10th Cir. 2002) (harassment and intentional demeaning conduct in confinement settings)