By: Kaitlin Price
In Cantley v. West Virginia Regional Jail and Correctional Facility Authority, the Fourth Circuit affirmed the district court’s ruling granting Defendants summary judgment, but on alternate grounds. Plaintiffs Michael Cantely and Floyd Teter sued the West Virginia Regional Jail and Correctional Facility Authority under 42 U.S.C. § 1983 for damages and equitable relief related to the strip search each Plaintiff endured. The district court granted summary judgment for Defendants’ holding that the strip searches did not violate the Fourth Amendment or any clearly established laws.
The Fourth Circuit affirmed the district court’s grant of Defendants’ summary judgment motion regarding Plaintiff Cantley’s strip search. The court explained that in 2012 the Supreme Court in Florence v. Board of Chosen Freeholders of County of Burlington, held that “every detainee who will be admitted to the general population [of a jail] may be required to undergo a close visual inspection while undressed.” Here, Mr. Cantley had been arraigned before a magistrate who committed him to the general population of Western Regional Jail, thus a strip search was necessary. The officer did not use force or touch Mr. Cantely at all. The Supreme Court’s holding in Florence covers Mr. Cantley’s strip search; therefore, the Fourth Circuit affirmed the district courts grant of summary judgment for the Defendants.
The Fourth Circuit affirmed the district court’s ruling that granted Defendants summary judgment against Plaintiff Teter’s strip search claim, although based on different reasoning. The facts of Plaintiff Teter’s search are distinguishable from those of Plaintiff Cantley because Plaintiff Teter had not appeared before a magistrate and been committed to the general population of the jail, but instead was being held in a holding cell.
Even though the Florence case did not provide a reason for the strip search in Mr. Teter’s case, the Fourth Circuit still held summary judgment was appropriate under the doctrine of qualified immunity. The Court explained that qualified immunity entitles a defendant to summary judgment if there is no constitutional right violations or if the law was not “‘clearly establish’” at the time of defendant’s alleged misconduct.” The Court explained the law was not “clearly established” law regarding Defendants actions. Plaintiff relied on Logan v. Shealy,660 F.2d 1007 (4th Cir. 1981), to show the law was “clearly established” the law, however the facts in Logan are extremely distinguishable from the facts here. In Logan the plaintiff was strip searched soon before she was set to leave the facility, did not interact with other prisoners, was only at the facility for two hours, and was strip searched in a room with a transparent window. However, here Plaintiff Teter was strip searched prior to being placed in a holding cell where he might interact with other prisoners, spent a total of eleven hours at the facility, and the strip search was conducted in a private room.
Both Plaintiffs also brought claims against Defendants for delousing them. The Fourth Circuit affirmed the district court’s ruling that granted summary judgment for Defendants on these claims, however for different reasoning than the district court. The Court held that the Defendants were entitled to summary judgment against the delousing claim because the law did not clearly establish that the delousing policy was unconstitutional. The Court explained because at the time of the delousing, existing precedent did not clearly indicate the practice was unconstitutional the defendants are entitled to qualified immunity against the claims.
The Court also affirmed the district court’s denial of Plaintiffs’ pray for injunctive and declaratory relief because such relief is premature.