Arnzen, III, et al. v. Palmer, et al., No. 12-3634 (8th Cir. 2013)Annotate this Case
Plaintiffs, patients at the Iowa Civil Commitment Unit for Sex Offenders (CCUSO), filed a complaint under 42 U.S.C. 1983 challenging the placement of video cameras in CCUSO restrooms, and moved for a preliminary injunction to stop their use. The district court denied the motion as to cameras in the dormitory style restrooms but granted a preliminary injunction ordering that cameras in the traditional style bathrooms be pointed at the ceiling or covered with a lens cap. The administrators of CCUSO appealed the district court's grant of the preliminary injunction. The court concluded that by capturing images of patients while they occupy single-user bathrooms, CCUSO violated its patients' reasonable expectation of privacy, thus conducting a search under the Fourth Amendment, irrespective of whether there was some chance that those images would not be viewed. The court agreed with the district court that plaintiffs showed the requisite probability of success on their Fourth Amendment claim; plaintiffs established a threat of irreparable harm; plaintiffs' interests in this case outweighed the injuries that the injunction would inflict on other parties; and there was a greater public interest in protecting the Fourth Amendment rights of plaintiffs and their personal privacy and dignity against unwarranted intrusion by the State. Accordingly, the court affirmed the judgment.