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PLRA Bars Damages for Jail Strip Search Suit
A New Mexico federal district court applied the injury requirement of the Prison Litigation Reform Act to hold that two female pretrial detainees cannot recover damages for a Fourth Amendment claim of unreasonable strip searches.
The matter proceeded to a jury trial. The facts showed that while detained at the Bernalillo County Detention Center, detainees Sharon Maya and Lisa Martinez were subject to strip searches conducted by two male guards. At the close of the evidence, the defendants moved for judgment as a matter of law.
The Court granted relief by dismissing all counts. In doing so, The court noted that Maya testified she suffers from migraines as a result of emotional trauma from the strip searches. Martine attempted to commit suicide by taking pills shortly after the strip searches. The court found that neither of them suffered contusions, scrapes, marks, or other injuries during the search. As for Martinez, The court held that a few hours of lassitude and nausea, and the discomfort of having her stomach pumped is no more than a de minimus physical injury. “As such, their injuries could not overcome the physical injury requirement in 42 U.S.C. §1997(e)(a). The court did not say whether that requirement would be met if Martinez’s suicide attempt had been successful.
The physical injury requirement was further grounds to dismiss the substantive due process claim, which was not founded in any case because the defendants did not act with deliberate or reckless intent. The equal protection claim was barred for failing to exhaust administrative remedies.
Accordingly, the court dismissed all counts in the complaint. See: Maya v. City of Albuquerque, USDC, New Mexico, Case No:96-1257 DDJ/RCP. The unpublished opinion is available in PLN’s Briefbank.
The matter proceeded to a jury trial. The facts showed that while detained at the Bernalillo County Detention Center, detainees Sharon Maya and Lisa Martinez were subject to strip searches conducted by two male guards. At the close of the evidence, the defendants moved for judgment as a matter of law.
The Court granted relief by dismissing all counts. In doing so, The court noted that Maya testified she suffers from migraines as a result of emotional trauma from the strip searches. Martine attempted to commit suicide by taking pills shortly after the strip searches. The court found that neither of them suffered contusions, scrapes, marks, or other injuries during the search. As for Martinez, The court held that a few hours of lassitude and nausea, and the discomfort of having her stomach pumped is no more than a de minimus physical injury. “As such, their injuries could not overcome the physical injury requirement in 42 U.S.C. §1997(e)(a). The court did not say whether that requirement would be met if Martinez’s suicide attempt had been successful.
The physical injury requirement was further grounds to dismiss the substantive due process claim, which was not founded in any case because the defendants did not act with deliberate or reckless intent. The equal protection claim was barred for failing to exhaust administrative remedies.
Accordingly, the court dismissed all counts in the complaint. See: Maya v. City of Albuquerque, USDC, New Mexico, Case No:96-1257 DDJ/RCP. The unpublished opinion is available in PLN’s Briefbank.
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Related legal case
Maya v. City of Albuquerque
| Year | 1996 |
|---|---|
| Cite | USDC, New Mexico, Case No:96-1257 DDJ/RCP |
| Level | District Court |
| Injunction Status | N/A |