This case was filed in the U.S. District Court for the Northern District of Texas by persons subjected to strip-searches which occurred at a nightclub during a drug bust. 17 people sued; four were later dismissed. Most plaintiffs settled for $65,400 to be distributed among them. Three went on to trial, and were awarded $100 each in nominal damages and $15,000 each in punitive damages against the sheriff. The court denied the injunction, saying it would be unnecessary/redundant. Williams v. Kaufman County, 86 F.Supp.2d 586 (N.D.Tex. Feb 07, 2000) (NO. CIV.A.3:97-CV-0875-L).
The judgment was affirmed by the Fifth Circuit in Williams v. Kaufman County, 352 F.3d 994 (5th Cir.(Tex.) Dec 09, 2003) (NO. 02-10500). The court (Judge Weiner) held that (1) absent individualized reasonable suspicion
or probable cause, the strip searches were unlawful; (2) the law was clearly established by the relevant time that strip-searching individuals, absent particularized reasonable suspicion or probable cause, was unlawful, thus precluding sheriff's entitlement to qualified immunity; (3) although the prolonged detention of plaintiffs was unlawful, the law was not clearly stablished that sheriff's generalized law enforcement safety interests
were insufficient to permit the detention until search's completion, and so
the district court properly granted qualified immunity on the unlawful detention
claims; (4) plaintiffs' invasion-of-privacy claim was redundant, to the extent based on the Fourth Amendment; (5) plaintiffs failed to assert a separate,
equal protection claim arising from officers' use of racial epithets; (6) plaintiffs established county's municipal liability for their strip search and
detention; (7) the district court did not err in imposing nominal damages of $100.00 per plaintiff; (8) the record supported the district court's conclusion that sheriff acted with reckless indifference toward plaintiffs' constitutional rights, thus justifying an award of punitive damages; (9) punitive damages of $15,000.00 per plaintiff were not excessive; and (10) declaratory relief granted plaintiffs for defendants' violation of the Texas Constitution was appropriate.
Denise Heberle - 08/14/2012
compress summary