University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Wood v. Clemons PC-ME-0005
Docket / Court 2:94-cv-00246-DBH ( D. Me. )
State/Territory Maine
Case Type(s) Prison Conditions
Special Collection Strip Search Cases
Case Summary
On August 19, 1994, represented by private counsel, a group of prison visitors filed a class action civil rights lawsuit pursuant to 42 U.S.C. § 1983 in the United States District Court for the District of Maine, challenging the strip-search policies of the Maine Correctional Center relative to ... read more >
On August 19, 1994, represented by private counsel, a group of prison visitors filed a class action civil rights lawsuit pursuant to 42 U.S.C. § 1983 in the United States District Court for the District of Maine, challenging the strip-search policies of the Maine Correctional Center relative to prison visitors. They claimed they were subjected to unconstitutional strip searches by prison officials when the plaintiffs attempted to visit their incarcerated relatives. Plaintiffs sought damages, declaratory and injunctive relief and certification on behalf of a statewide class of individuals affected by the alleged strip-search policies of the Maine Correctional Center.

Prison officials denied the allegations and maintained that the searches were lawful as they had received information from a confidential information (and, mistakenly, believed the information had been corroborated) that plaintiffs were attempting to smuggle drugs into the prison. On November 3, 1994, the plaintiffs sought to file an amended complaint, seeking the same relief and alleging constitutional violations and common law torts arising out of the strip searches. The parties filed cross-motions for summary judgment and plaintiffs moved for class certification and leave to file the second amended complaint.

The pretrial motions were referred to U.S. Magistrate Judge Eugene W. Beaulieu. On September 29, 1995, he issued his report recommending granting the defendants' motion for summary judgment and denying the plaintiffs' motions for class certification and for leave to file the amended complaint.

On December 8, 1995, in an unpublished order, the district court (Judge D. Brock Hornby) adopted the recommendations of the magistrate judge and entered summary judgment in favor of the defendant prison officials, finding that they were entitled to qualified immunity. Plaintiffs appealed. The U.S. Circuit Court of Appeals for the First Circuit (Circuit Judge Sandra Lea Lynch) affirmed, holding that (1) constitutionality of prison-visitor strip searches was governed by the standard of reasonable suspicion, and (2) on the facts presented (reasonable reliance on a mistaken report by an experienced staff member, with no evidence of deliberate or systematic misreporting), the prison officials were entitled to qualified immunity. Wood v. Clemons, 89 F.3d 922 (1st Cir. 1996).

No further action by the parties took place in this case.

Mike Fagan - 04/29/2008


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Issues and Causes of Action
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Issues
Affected Gender
Female
Male
General
Juveniles
Search policies
Strip search policy
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) Maine Correctional Center
Plaintiff Description Statewide class of individual prison visitors affected by the alleged strip-search policies of the Maine Correctional Center.
Indexed Lawyer Organizations None on record
Class action status sought Yes
Class action status granted No
Prevailing Party Defendant
Public Int. Lawyer No
Nature of Relief None
Source of Relief None
Form of Settlement None on record
Order Duration not on record
Case Closing Year 1996
Case Ongoing No
Additional Resources
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Case Studies Civil Rights Injunctions Over Time: A Case Study of Jail and Prison Court Orders
N.Y.U. Law Review
By: Margo Schlanger (Washington University)
Citation: 81 N.Y.U. L. Rev. 550 (2006)
[ Detail ] [ PDF ] [ External Link ]

  Jail Strip-Search Cases: Patterns and Participants
http://law.duke.edu/journals/lcp
By: Margo Schlanger (Washington University in St. Louis)
Citation: 71 Law & Contemp. Problems 65 (2008)
[ Detail ] [ External Link ]

  Judicial Policy Making and the Modern State: How the Courts Reformed America's Prisons
By: Malcolm M. Feeley & Edward Rubin (UC Berkeley Boalt Hall School of Law & Vanderbilt School of Law Faculty)
Citation: (1998)
[ Detail ]

Docket(s)
94-00246 (U.S. Court of Appeals) 09/18/1996
PC-ME-0005-9001.pdf | Detail
PACER [Public Access to Court Electronic Records]
2:94-cv-00246-DBH (D. Me.) 07/22/1998
PC-ME-0005-9000.pdf | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Opinion 07/22/1996 (89 F.3d 922)
PC-ME-0005-0001.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Judges Campbell, Levin Hicks (First Circuit, D. Mass.)
PC-ME-0005-0001
Hornby, David Brock (D. Me.) [Magistrate]
PC-ME-0005-9000
Lynch, Sandra Lea (First Circuit)
PC-ME-0005-0001
Torruella, Juan R. (First Circuit, D.P.R.)
PC-ME-0005-0001
Monitors/Masters None on record
Plaintiff's Lawyers Brown, Rufus E. (Maine)
PC-ME-0005-9000
Whitman, John S. (Maine)
PC-ME-0005-0001
Defendant's Lawyers Sleek, Diane (Maine)
PC-ME-0005-0001 | PC-ME-0005-9000
Other Lawyers None on record

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