In a matter of first impression, the U.S. Court of Appeals for the Eleventh Circuit issued an opinion finding a blanket strip search performed on a woman visiting a Georgia prison could not defeat the qualified immunity of offending officers because no Supreme Court nor Eleventh Circuit precedent “clearly established” a standard of reasonable suspicion for conducting searches at the time of the incident.

Judges Robin Rosenbaum, Kevin Newsom and Gerald Tjoflat formed the circuit’s panel. Rosenbaum wrote the majority opinion, issued on July 29, while she and Judge Kevin C. Newsom offered separate concurring opinions calling on the Eleventh Circuit to fix qualified-immunity jurisprudence.