West v. Murphy, No. 13-2014 (4th Cir. 2014)Annotate this Case
Plaintiffs represented a certified class of individuals arrested between certain dates on charges not involving weapons, drugs, or felony violence, and strip searched prior to or without presentment before a court commissioner or other judicial officer. Plaintiffs filed suit against defendants, two former wardens of Central Booking, challenging the strip searches of arrestees in Central Booking. The court concluded that the Supreme Court's intervening decision in Florence v. Board of Chosen Freeholders of County of Burlington, which came down almost four years after the class period closed, does not demonstrate that the law on jail strip searches either was or was not clearly established at the time these alleged searches were conducted. The district court correctly concluded that defendants are entitled to qualified immunity because the law did not clearly establish at the time that the searches that were conducted were unlawful. Accordingly, the court affirmed the district court's grant of defendants' motion for summary judgment on the grounds of qualified immunity.