Cheryl A. Munday and Margaret Devine, on behalf of themselves and others similarly situated v. Beaufort County

Summary

This document contains findings of fact and conclusions of law from a bench trial in a putative class action involving Beaufort County’s practice of strip-searching female pre-classification detainees at the Beaufort County Detention Center while not subjecting similarly situated male detainees to the same practice. The court addresses whether Beaufort County may be held municipally liable under 42 U.S.C. § 1983 pursuant to Monell. The court concludes that the detention center’s director possessed final policymaking authority and that the county may therefore be subject to municipal liability.

Holdings

1. Director Grant was the final policymaker for Beaufort County concerning the policies and procedures of BCDC because she exercised authority-in-fact to create and implement final policy, and her decisions were not subject to meaningful review by the County Council or County Administrator.
2. Beaufort County may be subject to municipal liability under 42 U.S.C. § 1983 because the challenged strip-search policy was adopted by Director Grant, who possessed final policymaking authority for Beaufort County concerning BCDC.

Questions Presented

1. Whether Director Grant possessed final policymaking authority for Beaufort County concerning the policies and procedures of the Beaufort County Detention Center.
2. Whether Beaufort County may be subject to municipal liability under 42 U.S.C. § 1983 for the strip-search policy that allegedly violated the Equal Protection Clause by subjecting female pre-classification detainees to strip searches while not subjecting male pre-classification detainees to the same practice.

Disposition

other