Case: Masters v. Crouch

3:87-cv-00450 | U.S. District Court for the Western District of Kentucky

Filed Date: July 23, 1987

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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 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 …

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.

Summary Authors

Blase Kearney (5/7/2012)

People


Judge(s)

Lively, Pierce (Kentucky)

Merritt, Gilbert Stroud Jr. (Tennessee)

Milburn, Herbert Theodore (Tennessee)

Attorney for Plaintiff

Bolzle, Gregory A. (Kentucky)

Lilly, N. Scott (Kentucky)

Judge(s)

Lively, Pierce (Kentucky)

Merritt, Gilbert Stroud Jr. (Tennessee)

Milburn, Herbert Theodore (Tennessee)

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Documents in the Clearinghouse

Document

88-05477

Opinion

U.S. Court of Appeals for the Sixth Circuit

April 18, 1989

April 18, 1989

Order/Opinion

872 F.2d 872

89-00576

[Opinion Denying Cert.]

Frey v. Masters

Supreme Court of the United States

Nov. 27, 1989

Nov. 27, 1989

Order/Opinion

493 U.S. 493

Docket

Last updated Feb. 26, 2024, 3:11 a.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: Kentucky

Case Type(s):

Jail Conditions

Special Collection(s):

Strip Search Cases

Key Dates

Filing Date: July 23, 1987

Case Ongoing: No reason to think so

Plaintiffs

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.

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: Unknown

Filed Pro Se: Unknown

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Jefferson County (Jefferson), County

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Due Process

Unreasonable search and seizure

Available Documents:

Any published opinion

Outcome

Prevailing Party: Unknown

Nature of Relief:

Unknown

Source of Relief:

Unknown

Issues

General:

Over/Unlawful Detention

Search policies

Strip search policy

Affected Sex or Gender:

Female

Type of Facility:

Government-run