Brown v. Polk County, No. 19-2698 (7th Cir. 2020)Annotate this Case
Brown, a detainee at Wisconsin’s Polk County Jail, underwent a physical search of her body cavities. The institution had a written policy authorizing such a search to be conducted by medical personnel when there was reasonable suspicion to believe an inmate was internally hiding contraband. Fellow inmates had reported that Brown was concealing methamphetamine inside her body, which prompted jail staff to invoke the policy. Officers took Brown to a hospital, where a doctor and nurse first conducted an ultrasound, then inspected both her vagina and rectum in a private room without officers present. The search revealed no drugs. Brown sued under 42 U.S.C. 1983, alleging violation of her Fourth Amendment rights. The district court granted the defendants summary judgment. The Seventh Circuit affirmed. The defendants had reasonable suspicion that Brown was concealing contraband, their suspicion justified the cavity search, and the ensuing search was reasonable.