Gustafson v. Adkins

Dist. Ct. did not err in denying defendant-detective’s motion for summary judgment alleging qualified immunity in section 1983 action asserting that defendant’s installation of hidden surveillance camera in female changing area in plaintiff’s workplace constituted violation of her 4th Amendment rights as unlawful search. Scope of employee’s 4th Amendment rights to be free from unreasonable searches in workplace was clearly established at time of installation of hidden camera. Moreover, reasonable official would have known that installation of hidden camera in changing area was unreasonable. Ct. further rejected defendant’s claim that instant section 1983 claim was precluded by either Civil Service Reform Act and/or Federal Employee’s Compensation Act.