Prisoner's 8th Amendment claim dismissed; 4th Amendment claim will go to trial.
23-year old Martinique Stoudemire suffered from a number of serious maladies including lupus and hypercoagulopathy that left her prone to heart attack and amputations. She was sent to prison at Huron Valley in Ypsilanti for a five-year felony term. She claimed that while in the prison, her health was neglected by authorities resulting in a heart attack, multiple amputations, and a MRSA infection. She claimed she was improperly confined in solitary for several weeks because of the MRSA infection, even though facilities there were not adequate for a wheelchair-bound patient with double amputations. She also claimed that she was subjected to an overly-intrusive strip search in her cell. She filed suit alleging violation of her civil rights protecting against "cruel and unusual punishment" and "unreasonable search and seizure."
The trial judge denied the individual defendants qualified immunity under section 1983 and they appealed to the Sixth Circuit. On appeal, the higher court agreed that the guard who performed the strip search without allowing any form of privacy protection was not entitled to qualified immunity; she would be required to prove the reasonableness of her actions. With regard to the inadequate health care claim, however, the Court reversed: it held that while Stoudemire may have received inadequate or negligent health care, the Constitutional standard required proof of more than neglect. On that basis, this claim was dismissed.