University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Masters v. Crouch JC-KY-0010
Docket / Court Unknown ( W.D. Ky. )
State/Territory Kentucky
Case Type(s) Jail Conditions
Special Collection Strip Search Cases
Case Summary
Plaintiff, an arrestee on a mistaken warrant, filed this 42 U.S.C. § 1983 lawsuit against Jefferson County in the Federal Court for the Western District of Kentucky. The plaintiff, represented by private counsel sought damages, declaratory and injunctive relief, claiming that her arrest and ... read more >
Plaintiff, an arrestee on a mistaken warrant, filed this 42 U.S.C. § 1983 lawsuit against Jefferson County in the Federal Court for the Western District of Kentucky. The plaintiff, represented by private counsel sought damages, declaratory and injunctive relief, claiming that her arrest and detention violated her Fourth and Fourteenth Amendment rights. Specifically, plaintiff claimed that an arrest stemming from an erroneously issued bench warrant, and the associated strip search, conducted in view of others at the county jail, violated her constitutional rights.

On July 31, 1986, the plaintiff was issued traffic citations for failure to maintain auto insurance and expired plates. She appeared twice in court in the matter, and was issued a reminder card that her next hearing was on October 23rd. A magistrate judge erroneously scheduled the hearing for October 16th, and plaintiff was arrested in her home on October 21st for her failure to appear on the 16th. The plaintiff showed the officers her reminder card and asked to call her attorney.

The police took the plaintiff to the county jail, and despite her insistence that she was not scheduled to appear on the 23rd, she was incarcerated and strip searched by an officer, in front of a window. She was then subjected to a full body search in which she was required to expose herself to an officer, though this was done in private. She was held until late in the evening and released on her own recognizance. The scheduling error was discovered the next morning and the charges were dismissed.

The district court (Judge Edward H. Johnstone) found that the defendants were not entitled to qualified immunity. An interlocutory appeal was granted.

On April 18, 1989, in a published opinion written by Pierce Lively, the Court of Appeals for the Sixth Circuit (Judges Lively, Gilbert Stround, and Herbert Milburn) found that the defendants were entitled to qualified immunity on the false arrest and detention claims, because the arrest warrant was facially valid. The Court found that the blanket policy of strip searching detainees was invalid under Bell v. Wolfish. The Court further found that a previous consent decree regarding conditions in the Jefferson County Jail did not preclude the Plaintiff from bringing a cause of action for violation of her constitutional rights. (872 F.2d 1248). The Court remanded for further proceedings.

Blase Kearney - 05/07/2012


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Issues and Causes of Action
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Issues
Affected Gender
Female
General
Over/Unlawful Detention
Search policies
Strip search policy
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) Jefferson County
Plaintiff Description Female plaintiff subjected to strip-search by female guards at the Jefferson County Jail in 1986, after she was arrested on a traffic warrant.
Indexed Lawyer Organizations None on record
Class action status sought No
Class action status granted No
Prevailing Party Unknown
Public Int. Lawyer No
Nature of Relief Unknown
Source of Relief Unknown
Form of Settlement None on record
Order Duration not on record
Case Closing Year n/a
Case Ongoing Unknown
Additional Resources
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Case Studies After Decision: Implementation of Judicial Decrees in Correctional Settings
Written: Oct. 01, 1977
By: M. Kay Harris & Dudley P. Spiller (Temple University)
Citation: (1977)
[ Detail ] [ PDF ]

  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 ]

Docket(s)
No docket sheet currently in the collection
General Documents
Opinion 04/18/1989 (872 F.2d 1248)
JC-KY-0010-0001 PDF | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
[Opinion Denying Cert.] 11/27/1989 (493 U.S. 977)
JC-KY-0010-0002 PDF | WESTLAW| LEXIS | Detail
Document Source: Westlaw
Judges Lively, Pierce (Sixth Circuit)
JC-KY-0010-0001
Merritt, Gilbert Stroud Jr. (Sixth Circuit)
JC-KY-0010-0001
Milburn, Herbert Theodore (E.D. Tenn, Sixth Circuit)
JC-KY-0010-0001
Monitors/Masters None on record
Plaintiff's Lawyers Bolzle, Gregory A. (Kentucky)
JC-KY-0010-0001
Defendant's Lawyers Lilly, N. Scott (Kentucky)
JC-KY-0010-0001
Other Lawyers None on record

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