Calhoun v. DeTella

319 F.3d 936 (2003)

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Calhoun v. DeTella

United States Court of Appeals for the Seventh Circuit
319 F.3d 936 (2003)

  • Written by Tammy Boggs, JD

Facts

Tyrone Calhoun (plaintiff) was a male prisoner at a correctional facility. According to Calhoun, prison guards removed him from his cell and made him strip for a search in an open area. Calhoun requested a more private location, but the guards ordered him to strip in front of several female officers who had no official role in the search process. The guards allegedly laughed at Calhoun, forced him to perform provocative acts, made sexual comments, and pointed their sticks toward his buttocks while he bent over. Calhoun was traumatized and asked for psychological treatment but received none. Thereafter, Calhoun sued the prison warden, George DeTella (defendant) for cruel and unusual punishment in violation of the Eighth Amendment. Calhoun sought different categories of damages and injunctive and declaratory relief. The trial court dismissed the complaint, finding that the Prison Reform Litigation Act, 42 U.S.C. § 1197e(e), barred the suit because Calhoun had not alleged any physical injury. Calhoun appealed. Calhoun’s request for injunctive and declaratory relief became moot on appeal because Calhoun was transferred to a different correctional facility, leaving only his claim for damages.

Rule of Law

Issue

Holding and Reasoning (Rovner, J.)

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