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Florence Strip-Search Decision Sends Iowa Case Back to Square One
The recent decision by the United States Supreme Court in Florence v. Board of Chosen Freeholders of the County of Burlington, 132 S.Ct. 1510 (2012), which held that every detainee, even one held on a non-indictable offense, who will be admitted to the jail’s “general population” may be required to undergo a close visual inspection while undressed without reasonable suspicion that the detainee is hiding contraband.
Plaintiffs Maureen Rattray, Lisa Lambert, and Lori Mathes, were arrested on serious misdemeanor charges in Iowa and taken to the Woodbury County Jail for booking and strip-searched according to the existing jail policy. The defendants acknowledge that all strip-searches were conducted without any reasonable suspicion that the parties might possibly be concealing contraband on their persons. The parties disagreed on the extent and invasiveness of the respective searches.
It was also undisputed that the three separate defendants never shared a holding cell, and Lambert and Mathes were never admitted to the general population of the jail, both being held less than 24 hours.
The Iowa court had originally granted summary judgment on behalf of Rattray on her claim that the previous jail strip-search policy violated her rights, and a jury awarded her damages on that claim prior to the decision in Florence. The other two defendants’ cases had not been disposed of prior to Florence. The Iowa court then stayed all proceedings until the Supreme Court’s Florence opinion was made public.
After Florence, the county and jail administrators filed motions for summary judgment, seeking dismissal of all three separate claims. The Iowa court then ruled that “summary judgment in favor of the County is appropriate on all of the plaintiffs’ ‘no reasonable suspicion’ strip searches claim, in light of this (new) standard from Florence.”
However, the first two plaintiffs, Rattray and Lambert, had objected to the “manner” of the searches, and as a result, the judge ruled that these particular claims could survive Florence, which refused to articulate what manner of strip searches might be deemed overly invasive or objectionable, and set the two cases for trial. Mathes’ claim was dismissed. See: Rattray v. Woodbury County, Iowa, U.S.D.C. (N.D. Iowa), Case No. 5:07-cv-04014-MWB.
Plaintiffs Maureen Rattray, Lisa Lambert, and Lori Mathes, were arrested on serious misdemeanor charges in Iowa and taken to the Woodbury County Jail for booking and strip-searched according to the existing jail policy. The defendants acknowledge that all strip-searches were conducted without any reasonable suspicion that the parties might possibly be concealing contraband on their persons. The parties disagreed on the extent and invasiveness of the respective searches.
It was also undisputed that the three separate defendants never shared a holding cell, and Lambert and Mathes were never admitted to the general population of the jail, both being held less than 24 hours.
The Iowa court had originally granted summary judgment on behalf of Rattray on her claim that the previous jail strip-search policy violated her rights, and a jury awarded her damages on that claim prior to the decision in Florence. The other two defendants’ cases had not been disposed of prior to Florence. The Iowa court then stayed all proceedings until the Supreme Court’s Florence opinion was made public.
After Florence, the county and jail administrators filed motions for summary judgment, seeking dismissal of all three separate claims. The Iowa court then ruled that “summary judgment in favor of the County is appropriate on all of the plaintiffs’ ‘no reasonable suspicion’ strip searches claim, in light of this (new) standard from Florence.”
However, the first two plaintiffs, Rattray and Lambert, had objected to the “manner” of the searches, and as a result, the judge ruled that these particular claims could survive Florence, which refused to articulate what manner of strip searches might be deemed overly invasive or objectionable, and set the two cases for trial. Mathes’ claim was dismissed. See: Rattray v. Woodbury County, Iowa, U.S.D.C. (N.D. Iowa), Case No. 5:07-cv-04014-MWB.
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Related legal case
Rattray v. Woodbury County, Iowa
| Year | 2012 |
|---|---|
| Cite | U.S.D.C. (N.D. Iowa), Case No. 5:07-cv-04014-MWB |
| Level | District Court |