This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
In March 1992, two high school students were subjected to strip searches by school officials in an attempt to recover a missing diamond ring. The searches involved invasive procedures, including requiring one student to expose her breasts and another to pull his underwear away from his body. The searches were conducted without individualized suspicion and caused significant distress to the students (paras 1, 3-5).
Procedural History
- Kennedy v. Dexter Consolidated Schools, 1998-NMCA-51: The Court of Appeals affirmed compensatory damages against the school district but reversed judgments against individual defendants, citing qualified immunity and errors in jury instructions. It also overturned punitive damages and attorney's fees awards (para 1).
Parties' Submissions
- Plaintiffs: Argued that the strip searches violated their Fourth Amendment rights and sought damages under 42 U.S.C. § 1983. They contended that the searches were unjustified, excessively intrusive, and conducted without individualized suspicion (paras 1, 6, 8).
- Defendants: Asserted qualified immunity, arguing that the searches did not violate clearly established law in 1992. They also challenged the jury instructions and the sufficiency of evidence supporting punitive damages and attorney's fees (paras 7-8, 10, 34).
Legal Issues
- Did the strip-to-undergarments search of one student violate clearly established law in 1992, thereby negating qualified immunity for school officials?
- Were the specific involvements of certain school officials sufficient to hold them liable under Section 1983?
- Did the erroneous jury instruction on pre-search detention constitute reversible error?
- Was the evidence sufficient to support the punitive damages awarded against certain defendants?
- Were attorney's fees properly awarded in the absence of detailed time records?
Disposition
- The Supreme Court of New Mexico reversed the Court of Appeals' rulings on compensatory and punitive damages, reinstating the trial court's judgments except for attorney's fees, which were remanded for further proceedings (paras 2, 38-39).
Reasons
Per Franchini J. (Minzner C.J., Baca, Serna, and Maes JJ. concurring):
Qualified Immunity: The Court held that the strip-to-undergarments search violated clearly established Fourth Amendment rights in 1992. The lack of individualized suspicion and the excessive scope of the searches rendered them unconstitutional. The Court rejected the distinction between full nudity and partial nudity as a basis for qualified immunity (paras 11-19).
Liability of School Officials: The Court found sufficient evidence to hold Counselor Perry and Superintendent Derrick liable. It ruled that the Court of Appeals improperly reweighed evidence regarding their involvement in the searches (paras 20-22).
Jury Instruction: The erroneous jury instruction on pre-search detention was deemed harmless. The Court concluded that the jury's verdict was based solely on the illegal search claim, as evidenced by the exoneration of a defendant responsible for the detention (paras 23-30).
Punitive Damages: The Court reinstated punitive damages against Counselor Perry and Ms. Rodriguez, finding sufficient evidence of willful, wanton, or reckless conduct. Their actions demonstrated indifference to the students' constitutional rights (paras 31-33).
Attorney's Fees: The Court affirmed the reversal of attorney's fees, holding that detailed time records are required to calculate fees under the lodestar method. It remanded the issue for further proceedings (paras 34-37).