Gustafson v. Adkins, No. 15-1055 (7th Cir. 2015)
Annotate this CaseIn 2007, Adkins, a detective at a Chicago Veterans Affairs (VA) Medical Center, installed a hidden surveillance camera in the ceiling of an office used by female officers as a changing area. The camera captured images of female officers dressing and undressing. VA personnel discovered the covert surveillance equipment during a 2009 renovation. Gustafson learned that the camera had captured images of her changing and filed suit against Adkins, alleging an unconstitutional search in violation of the Fourth Amendment. The district court denied Adkins’s motion for summary judgment on qualified immunity grounds. The Seventh Circuit affirmed, rejecting Adkins’s claims that Gustafson’s Bivens claim was precluded by the “comprehensive remedial scheme[s]” laid out in the Civil Service Reform Act and the Federal Employees’ Compensation Act. Supreme Court precedent clearly established the contours of the Fourth Amendment violation Gustafson alleged.
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