Patrick R. Kurkowski v. Austin Spafford, Tanner Pardun, Officer Magnun, Melissa McLain, and Raye Ward

Summary

The United States District Court for the Western District of Wisconsin granted summary judgment to jail officials in Patrick R. Kurkowski's Fourteenth Amendment action concerning an allegedly excessive and sexually inappropriate pat-down search. The court concluded that the undisputed facts and video evidence showed that the search was objectively reasonable and directed entry of judgment for defendants and closure of the case.

Holdings

1. The pat-down search did not violate Kurkowski's Fourteenth Amendment rights because it was objectively reasonable and not excessive in relation to the legitimate governmental objective of locating a razor blade and medication.
2. Defendants were entitled to summary judgment because the material facts were undisputed and the record evidence, particularly the video footage, showed that Spafford's conduct was constitutional.

Questions Presented

1. Whether the pat-down search violated Kurkowski's Fourteenth Amendment due process rights because it was objectively unreasonable or excessive in relation to the legitimate governmental objective of locating contraband.
2. Whether defendants were entitled to summary judgment based on the undisputed facts and video evidence.
3. Whether the court needed to address qualified immunity or the claims that the other defendants failed to intervene.

Disposition

other