Background
Latonya Griffin sued Sheriff Eric Aden and deputies Rapheal Brown and Grady Carpenter following a search warrant execution at her home in August two thousand and nineteen. During the operation, Griffin was ordered outside fully nude and detained for approximately forty minutes before being allowed to dress. She alleged the circumstances violated her Fourth Amendment rights and state law. The district court granted summary judgment to all defendants, finding no constitutional violation and granting qualified immunity.
The court’s reasoning
The court concluded that while detentions during search warrants are generally reasonable, the manner of execution here raised genuine issues of material fact. The evidence, viewed in the light most favorable to Griffin, suggested she was detained in unusually demeaning conditions for longer than necessary for safety or investigatory reasons. The court found that a reasonable jury could conclude the deputies violated her right to bodily privacy. Regarding qualified immunity, the court held that Defendant Carpenter, the supervising deputy, is not entitled to immunity because the unlawfulness of such conduct was clearly established. However, Defendant Brown’s role was limited, and he remains entitled to immunity. The court also vacated the summary judgment against the Sheriff, ruling that the district court erred in dismissing the negligence claim under Florida law.
What it means going forward
The decision allows Griffin’s Fourth Amendment claim against the supervising deputy to proceed to trial and requires the district court to reconsider the negligence claim against the Sheriff.