Eighth Circuit Upholds Injunction Over Cameras in Restrooms at Civil Commitment Center
by Matt Clarke
In April 2013 the Eighth Circuit Court of Appeals upheld a preliminary injunction granted by a federal district court in a lawsuit challenging the placement of video cameras in bathrooms at the Iowa Civil Commitment Unit for Sex Offenders, a secure facility.
John W. Arnzen III, Harold Williams, Galen K. Shaffer and Edward Lee Briggs, patients at the Civil Commitment Unit, filed a civil rights action pursuant to 42 U.S.C. § 1983, alleging that installing cameras in the restrooms at the Unit violated the Fourth Amendment’s prohibition against unreasonable searches and their right to privacy. They then sought a preliminary injunction.
The district court denied the injunction with respect to multi-user bathrooms (those with multiple toilets, showers and sinks), and granted it with respect to single-user restrooms (those with a single toilet, shower and sink). The defendants appealed.
On appeal, administrators at the Civil Commitment Unit argued that the cameras were installed after a reported sexual assault and an incident in which a patient with a serious communicable disease engaged in consensual sex without informing the other patient of his disease. Although the cameras are not monitored and the video recordings are destroyed within two to three weeks unless they are being used in an investigation, the administrators claimed the cameras prevented assaults and other illicit behavior, and argued the district court should have deferred to their judgment as qualified professionals.
Reviewing the grant of the preliminary injunction under an abuse of discretion standard, the Eighth Circuit held the plaintiffs had the same Fourth Amendment rights as pretrial detainees. The appellate court noted that the patients had expressed more than just a general discomfort and embarrassment; they were victims of childhood sexual abuse, and “persuasively report[ed] significant on-going trauma and distress related to the placement of cameras in their bathrooms, which they, in sometimes eloquent and disturbing detail, equate with their previous experiences of victimization.”
The Court of Appeals wrote that while the unmonitored cameras might help deter illicit behavior and assist in investigations, they “do not provide immediate alerts concerning patient safety or directly prevent assaults or dangerous acts.” Even the defendants acknowledged that providing restroom doors that lock from the inside could significantly reduce the risk of assaults. Also, since the entrances to the bathrooms are actively monitored via video cameras, staff could immediately investigate when more than one person enters a single-user restroom. Thus, the cameras are not the only way – and may not be the most effective way – to prevent assaults and illicit sexual activity in restroom areas.
The Eighth Circuit found “that in the circumstances of this case there is a greater public interest in protecting the Fourth Amendment rights of the patients and their ‘personal privacy and dignity against unwarranted intrusion by the State,’” and therefore affirmed the district court’s preliminary injunction order. See: Arnzen v. Palmer, 713 F.3d 369 (8th Cir. 2013).
The case settled following remand, with the defendants agreeing to remove the video cameras in restrooms at the Civil Commitment Unit and to ensure that cameras in the hallways outside bathrooms “do not show patients in the shower or on the toilet.” Further, the defendants agreed to pay $22,000 in attorney’s fees and to give $100 in commissary or shopping account credit to each of the four plaintiffs. See: Arnzen v. Palmer, U.S.D.C. (N.D. Iowa), Case No. 5:12-cv-04001-DEO.
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Related legal cases
Arnzen v. Palmer
|Cite||713 F.3d 369 (8th Cir. 2013)|
|Level||Court of Appeals|
Arnzen v. Palmer
|Cite||U.S.D.C. (N.D. Iowa), Case No. 5:12-cv-04001-DEO|