Collins v. Davis

Background

Scott Forrest Collins, who was representing himself and was confined at San Quentin State Prison, sued Ron Davis, the prison’s warden, in both his official and individual capacities. Collins challenged the prison’s policy for conducting unclothed body searches, also called strip searches, of condemned inmates. He asserted claims under the First Amendment, the Religious Land Use and Institutionalized Persons Act (RLUIPA), the Fourth Amendment, the Eighth Amendment, and the Fourteenth Amendment. He sought an injunction, compensatory damages, and punitive damages.

Collins was housed in the East Block. Under the prison manual, condemned Grade A prisoners in East Block were required to undergo an unclothed body search before leaving their cells and when returning after having an opportunity to obtain contraband. The searches included a visual inspection of the prisoner’s body and clothing, did not involve touching, and were conducted with measures intended to limit visibility. Collins said that, since September 2016, he had undergone approximately 1,000 such searches and had missed religious services, showers, and exercise time to avoid them.

Davis argued that routine searches were needed because of safety and security risks in the condemned housing units, including the risk that prisoners could conceal weapons or other contraband. Collins argued that searches should instead be unannounced, random, and no more frequent than necessary for security purposes.

First Amendment claim

The court applied the four-part test from Turner v. Safley, which asks whether a prison rule is reasonably related to legitimate prison interests. The court concluded that Davis had shown a rational connection between routine strip searches and the prison’s interests in protecting staff and prisoners and detecting contraband. The court also found that Collins had not provided enough evidence that the policy was an exaggerated response to those concerns or that his proposed random-search alternative would adequately protect security.

The court recognized that strip searches are a substantial invasion of privacy and that their routine use made the intrusion more serious. But it gave substantial deference to prison administrators and considered Collins’s death sentence, maximum-security classification, housing assignment, and the security concerns associated with his unit. The court held that Collins had not raised a genuine factual dispute for trial and granted Davis summary judgment on the First Amendment claim.

RLUIPA claim

RLUIPA prohibits a state from substantially burdening an institutionalized person’s religious exercise unless the burden furthers a compelling government interest and is the least restrictive means of doing so. The court assumed, for purposes of the motion, that Collins’s attendance at religious services qualified as religious exercise. It nevertheless held that Collins had not shown a substantial burden because he did not explain the nature or severity of the burden or show that the policy forced him to act contrary to his religious beliefs. His statement that he had missed services to avoid strip searches was insufficient. The court therefore did not reach the other elements of the RLUIPA claim and granted Davis summary judgment on it.

Fourth Amendment claim

The court analyzed whether the searches were unreasonable under the Fourth Amendment, applying the prison-security test from Turner together with the factors identified in Bell v. Wolfish, including the scope and manner of the intrusion, its justification, and where it occurred. The court again found a rational connection between the searches and prison safety and security because the policy applied when prisoners had an opportunity to obtain and conceal contraband.

The court concluded that Collins had not produced enough evidence to show that the policy was unreasonable or excessive in light of the deference owed to prison administrators. It granted Davis summary judgment on the Fourth Amendment claim.

Eighth Amendment claim

To prevail under the Eighth Amendment, Collins had to show both that the policy exposed him to a substantial risk of serious harm and that Davis acted with deliberate indifference. The court found no evidence that the searches were conducted in a demeaning or sexually abusive manner. Although the court acknowledged that routine strip searches are frightening and humiliating, it held that Collins had not shown that they deprived him of life’s basic necessities or created a substantial risk of serious harm.

The court further held that Collins had not shown deliberate indifference because the record indicated that Davis implemented the policy to address prison safety and security. The court granted Davis summary judgment on the Eighth Amendment claim.

Fourteenth Amendment claims

For equal protection, Collins had to show that Davis intentionally treated him differently from similarly situated prisoners without a reasonable connection to a legitimate prison objective. Collins did not dispute that he was treated the same as other prisoners housed in East Block and offered no evidence of intentional discrimination by Davis. The court also had already found that the policy was reasonably related to prison security. It granted Davis summary judgment on the equal-protection claim.

For due process, Collins argued that he should not be strip-searched without first committing a rules violation and receiving disciplinary procedures. He also argued that Davis’s handling of his prison grievance violated due process. The court held that Collins identified no state policy creating the claimed liberty interest and did not show that the searches imposed an atypical and significant hardship in relation to ordinary life in his maximum-security housing unit. The court also held that prisoners do not have a constitutional right to a particular grievance or appeal procedure. It granted Davis summary judgment on the due-process claim.

Qualified immunity and damages

Qualified immunity protects government officials from damages when their conduct did not violate a clearly established constitutional right. Because the court found that Collins had not raised a triable issue that Davis violated any constitutional right, it concluded that Davis prevailed on the first part of the qualified-immunity inquiry.

The court also held that the Eleventh Amendment barred money damages against Davis in his official capacity. It held that RLUIPA did not authorize damages against a state official in either an official or individual capacity. Finally, the court held that punitive damages were unavailable because Collins had not shown that Davis acted with an evil motive or reckless indifference to Collins’s constitutional rights.

Disposition

The court granted Ron Davis’s motion for summary judgment.