Watson v. Jones

JurisdictionUnited States

Watson v. Jones

980 F. 2d 1165

Facts

Missouri Eastern Correctional Center inmates Joseph Watson and Bill Harris brought suit to the U.S. District Court for the Eastern District of Missouri alleging that Correctional Officer Marie Jones violated their Fourth Amendment rights by sexually harassing them for almost two months in 1990 while she performed daily routine pat-down searches. Watson and Harris contended that Jones tickled them while performing searches; deliberately examined genital, anus, lower stomach, and thigh areas routinely; and that Jones's searches often included prolonged rubbing and fondling of the genitals and anus area. Watson and Harris also alleged that when they informed Jones that they wished to be searched by male guards, she retaliated by citing them for false disciplinary violations. If they refused to be searched, they would be put in the "hole" Jones responded by noting that she only patted down the defendants six to seven times during the two-month period, and in accordance with Missouri correctional procedures, she never patted an inmate in the crotch unless she knew something was there. Jones denied touching the inmates' genital, anal, and upper thigh areas; she claims she touched the inmates' lower stomachs with the back of her hands in accordance with Missouri search procedures. The District Court dismissed Watson and Harris's suit by granting summary judgment to Jones, because the inmates presented only broad and conclusory allegations that Jones denied. Watson and Harris appealed.

Issue

Did Watson and Harris present enough specific evidence of sexual harassment in their favor to allow the District Court to find that Jones's pat-down searches of them violated their Fourth Amendment privacy rights?

Eighth Circuit Court of Appeals Holding

The Eighth Circuit Court of Appeals reversed the District Court's summary judgment order and remanded the case for further proceedings after finding that the evidence produced by Watson and Harris was more than broad and conclusory, and could entitle the inmates to a legal judgment in their favor.

Reason

In this case, the first issue for the Eighth Circuit Court of Appeals to decide was whether the District Court's summary judgment order was based on the inmates presenting only broad and conclusory evidence. The Circuit Court...

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