Hill v. McKinley

United States Court of Appeals for the Eighth Circuit · Torts

TortsSection 1983Fourth Amendment privacyQualified immunityInvasion of privacyIntrusion upon seclusionqualified immunityFourth Amendment

Facts

After Hill was arrested for public intoxication, she was taken to jail, was loud and uncooperative, and was placed naked in a padded cell under jail policy. Near shift change, guards decided to move her from the padded cell to a restraining board for safety reasons, and they transferred her naked through the jail to another room where she was strapped face-down, spread-eagled, and naked. No one other than the defendant guards saw her naked, but viewing the evidence favorably to Hill, the court assumed she remained completely exposed to male guards for a substantial period after she was restrained. Hill claimed this conduct violated her Fourth Amendment privacy rights and also constituted intrusion upon seclusion under Iowa law.

Issue

Whether the guards were entitled to qualified immunity on Hill's Fourth Amendment privacy claim arising from requiring her to disrobe, transferring her nude, and restraining her nude in the presence of male guards; and whether the evidence was sufficient to support Hill's Iowa intrusion-upon-seclusion claim and damages award.

Rule

In qualified immunity analysis, the court first asks whether the facts establish a constitutional violation and then whether the right was clearly established in the specific context of the case. A right is clearly established only when preexisting law makes the unlawfulness of the conduct apparent to a reasonable official. Under Iowa law, intrusion upon seclusion requires an intentional intrusion upon another's solitude or seclusion that would be highly offensive to a reasonable person.

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Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Cedar Rapids, Iowa, jail officers placed Dana Ortiz, an intoxicated detainee, in a padded cell after she repeatedly slammed her head against the wall and tried to bite an officer. No female officer was available, so a male officer stood nearby while a female officer ordered Dana to remove her clothing before placement in the cell under a safety policy.

Assuming Dana sues under § 1983 for violation of her Fourth Amendment privacy rights, which is the best answer?

Explanation. The majority distinguished immediate, safety-based measures from unnecessary continued exposure. It held that requiring a loud and violent female prisoner to disrobe before placement in a padded cell for her own safety did not violate the Fourth Amendment, even with male-guard involvement. The key is the justification grounded in safety and the limited scope of the exposure.