Ingram v. Cole County, No. 16-1046 (8th Cir. 2017)
Annotate this CasePlaintiffs, detainees at the Cole County Detention Center, filed two putative class actions, one for current detainees and one for former ones, alleging that the laundry policy violates the Eighth and Fourteenth Amendments to the United States Constitution and corresponding provisions of the Missouri Constitution. The laundry policy allows guards and cellmates to see detainees naked while the detainees' one set of jail-issued clothing is being washed every few days. The detainees are given a bed sheet and a blanket. The court concluded that this practice constitutes more than a de minimis deprivation, and this practice is not related to a legitimate government interest. Therefore, the laundry policy is unconstitutional and the district court erred in dismissing the complaint. Finally, because the district court based its qualified immunity ruling on the perceived lack of a constitutional violation, the district court also erred as to this issue. Accordingly, the court reversed the dismissal and remanded for further proceedings.
Court Description: Smith, Author, with Riley, Chief Judge, and Murphy, Circuit Judge] Prisoner case - Prisoner Civil Rights. Plaintiffs' challenge to the laundry policy at the Cole County Detention Center which leaves pretrial detainees naked, with only a sheet and a blanket for cover, every four nights for women and every two-to-three nights for men, alleges more than de minimis deprivation that is not related to a legitimate governmental purpose, and the district court erred in dismissing their complaint; because the district court based its qualified-immunity ruling on the perceived lack of a constitutional violation, that ruling is also reversed. Judge Murphy, concurring in part and concurring in the judgment.
The court issued a subsequent related opinion or order on July 30, 2018.
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