Brown v. Dickey, No. 23-1767 (1st Cir. 2024)

In Brown v. Dickey, No. 23-1767 (1st Cir. 2024), Jaden Brown, a pregnant inmate, sued correction officers Daniel Haskell and Sam Dickey for violating her Fourth Amendment rights while she was at Maine Medical Center for childbirth. Brown alleged that the officers observed her naked body during medical procedures and the delivery of her baby, which she claimed was an unlawful search.

The key legal issue was whether the officers’ presence and alleged observations constituted a violation of Brown’s Fourth Amendment rights. The United States District Court for the District of Maine denied Haskell and Dickey’s motion for summary judgment based on qualified immunity, concluding that there were genuine disputes of material fact regarding the nature of the officers’ observations. The court ruled that if the officers did observe Brown’s naked body, this would qualify as a search under the Fourth Amendment.

On appeal, the United States Court of Appeals for the First Circuit dismissed part of the appeal, stating that it lacked jurisdiction to review the officers’ claim that they did not observe Brown’s naked body, as this was a factual dispute. The appellate court affirmed the district court’s denial of summary judgment, agreeing that if the officers did witness Brown’s naked body, it could be considered a search under the Fourth Amendment. The court clarified that a search does not necessarily require deliberate intent to observe a naked body, and such an action could violate clearly established constitutional law, making qualified immunity inapplicable in this context.

Ultimately, the First Circuit upheld the district court’s decision, allowing the case to proceed to trial to resolve the factual disputes surrounding the officers’ conduct.