Williams v. City of Cleveland

Williams filed a purported class action against Cleveland, under 42 U.S.C. 1983, alleging that intake procedures at its House of Corrections (HOC), consisting of strip searches and mandatory delousing, violated the Fourth Amendment. On remand, after extensive discovery, the court granted Williams summary judgment in part and permanently enjoined the city from reinstituting its previous delousing method and from conducting group strip searches without installation of privacy partitions to obstruct the view of other inmates. The Sixth Circuit reversed. Williams did not have standing to seek declaratory or injunctive relief; she was not in custody when she filed suit and it must be assumed that she will not return to the HOC. The fact that Williams returned to the HOC three times after filing the complaint does not confer standing because the relevant inquiry is whether she had a live, actionable claim for relief at the time she filed suit. Cleveland had discontinued its delousing policy by 2011, when Williams returned to the HOC. Allowing strip searches to be conducted in groups of two or three during busy periods, such as Williams’s time of intake, was reasonably related to Cleveland's legitimate penological interest of expediting the intake procedure; delousing detainees with a fine mist was reasonably related to its interest in maintaining the HOC's cleanliness and habitability. The need for delousing outweighed the admittedly substantial invasion of personal rights. View "Williams v. City of Cleveland" on Justia Law