Latonya Griffin v. Eric Aden

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NOT FOR PUBLICATION

In the

United States Court of Appeals

For the Eleventh Circuit

____________________

No. 25-10929

Non-Argument Calendar

____________________

LATONYA GRIFFIN,

Plaintiff-Appellant,

versus

ERIC ADEN,

RAPHEAL BROWN,

GRADY CARPENTER,

Defendants-Appellees.

____________________

Appeal from the United States District Court

for the Northern District of Florida

D.C. Docket No. 3:23-cv-23988-TKW-ZCB

____________________

Before JORDAN, ROSENBAUM, and KIDD, Circuit Judges.

PER CURIAM:

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2 Opinion of the Court 25-10929

Latonya Griffin appeals the district court’s grant of summary

judgment on her civil-rights action under 42 U.S.C. § 1983 and state

law against Sheriff Eric Aden, in his official capacity, and Deputies

Rapheal Brown and Grady Carpenter, in their individual capacities.

Griffin’s claims arise from the execution of a search warrant at her

home in August 2019, during which she was ordered outside fully

nude and detained for approximately 40 minutes before being al-

lowed to dress. She alleged that the circumstances of her detention

were unreasonable and violated the Fourth Amendment and her

right to bodily privacy, and that the Sheriff is liable for the unrea-

sonable nude seizure under state law. The district court granted

summary judgment to Defendants, concluding that the deputies

did not violate Griffin’s constitutional rights or violate clearly es-

tablished law. Griffin appeals.

After careful review, we affirm in part and vacate and re-

mand in part. We hold that a reasonable jury could find that Grif-

fin’s right to bodily privacy was violated during the execution of

the search warrant, and that Defendant Carpenter, the supervising

deputy who oversaw Griffin’s detention, is not entitled to qualified

immunity. We affirm the grant of qualified immunity to Defend-

ant Brown, whose role in Griffin’s detention was much more lim-

ited. Finally, we vacate the grant of summary judgment to the

Sheriff, for reasons explained in more detail below.

I.

The record includes footage from multiple bodycam videos.

We recount the facts “in the light depicted by the video[s].” Scott

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v. Harris, 550 U.S. 372, 381 (2007). Where the video evidence is not

clear, we construe the facts in the light most favorable to Griffin.

Baxter v. Santiago-Miranda, 121 F.4th 873, 883 (11th Cir. 2024).

At dawn on August 29, 2019, Griffin was asleep upstairs in

her home with her two minor children and boyfriend, Tony

Streeter, when she awoke to loud banging noises at the front door.

Griffin attempted to wake Streeter, who did not respond, and then

left the bedroom unclothed.

Meanwhile, at around 5:45 a.m., an interagency task force

led by the Oskaloosa County Sheriff’s Office used a battering ram

to force open Griffin’s front door. Approximately fifteen law-en-

forcement officers had come to execute a search warrant targeting

Streeter, whom they suspected of selling drugs from the home.

The deputies supervising the search included Investigator Brown

and Lieutenant Carpenter, defendants here, as well as Sergeant Mi-

chael Rader. Brown was the lead case agent. He prepared the

search warrant and coordinated the search, while Defendant Car-

penter was the on-site search supervisor.

As Griffin reached the top of the stairs, she saw the deputies

at the threshold, with guns drawn and flashlights illuminated, and

heard orders to come down to the front door. A deputy announced

that Griffin was not wearing any clothes. Griffin complied with

orders to walk outside, but she loudly objected to being outside

naked.

When Griffin exited the residence at approximately 5:47

a.m., Carpenter saw that she was naked and asked for a covering

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4 Opinion of the Court 25-10929

to give her—a “towel” or “clothes” or “anything”—before direct-

ing her to stand behind a patrol car to stay out of sight. Another

deputy gave Griffin a yellow, reflective jacket from the trunk of the

car. 1 Carpenter said, “that’ll work,” and then turned his attention

back to the house. Griffin put on the waist-length jacket, which

went to the top of her hip, did not cover her genitalia or buttocks,

and “did not fit,” according to Griffin. At this time, it was still

mostly dark outside.

Meanwhile, Griffin’s 14-year-old son had exited the resi-

dence, and Carpenter directed him to stand by his mother. Griffin’s

son testified that his mom’s “whole body was exposed” and he tried

to shield her from view. He said that the rain jacket was “small”

and that her breasts and buttocks remained exposed. Several

minutes later, deputies went upstairs and brought Griffin’s 6-year-

old daughter outside to join her.

Griffin and her children were placed together in the back of

a patrol car and taken to the parking lot of a public shopping plaza

close to the residence. The plaza was located on Wright Parkway,

a public road. They remained in the patrol car until approximately

6:20 a.m.

“While in the rear of the patrol car,” Griffin testified, “the

jacket was removed, and [she] was left completely naked again

with [her] children seated to [her] left.” Griffin’s son likewise said

1 Body camera footage contradicts Griffin’s testimony that she was exposed in

her driveway for approximately 15 to 20 minutes before being given the jacket.

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that, when they were in the patrol car, Griffin “did not have any-

thing around her.” Body-cam footage shows her in the car without

the jacket on, with several deputies standing around the car. And

even assuming she had the jacket, as she indicated at her deposi-

tion, her lower body remained uncovered. Griffin also saw pass-

ersby looking at her and her children in the patrol car, and she at-

tempted to slump down to avoid being seen. Griffin was not al-

lowed to use the restroom and urinated on herself.

Meanwhile, Streeter remained inside the home and did not

respond to repeated police commands. He was eventually taken

into custody in his bedroom after being tased, at approximately

6:07 a.m. The deputies dressed him in shorts and then took him

downstairs at approximately 6:10 a.m.

At approximately 6:19 a.m., the patrol car containing Griffin

and her children returned and parked just off the main road, at the

entrance to the access road for Griffin’s and nearby homes. Griffin

was instructed to exit while an officer held up a white fitted sheet

for her to wrap herself in. Griffin testified that the sheet was “trans-

parent” but that it provided more coverage than the jacket. She

sobbed as she walked back towards her home.

Once inside, Griffin, still wearing only the fitted bed sheet,

was instructed to sit on a couch by her children while Brown read

the search warrant aloud. Body-cam footage shows the reflective

jacket on the floor at Griffin’s feet. After the reading of the warrant

was finished, Griffin was finally allowed to dress, accompanied by

a female deputy, at approximately 6:26 a.m.

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II.

Griffin sued Sheriff Aden, Investigator Brown, and Lieuten-

ant Carpenter in federal court, alleging that they had conducted an

unreasonable seizure that violated her privacy rights under the

Fourth Amendment. The operative amended complaint alleged

the following three counts: a vicarious-liability claim against the

Sheriff in his official capacity under Fla. Stat. § 768.28 (Count I); an

unreasonable-seizure claim against Brown in his individual capac-

ity under § 1983 (Count II); and a supervisory-liability claim against

Carpenter under § 1983 (Count III).

The district court granted summary judgment to Defend-

ants on all three claims. The court generally found that Defendants

did not violate Griffin’s right to bodily privacy. The court reasoned

that deputies were aware of the need to protect Griffin’s privacy,

and they took reasonable steps to ensure that her naked body was

not exposed longer than necessary while they secured the home to

execute the search warrant. The court also found that both Brown

and Carpenter were entitled to qualified immunity because Griffin

had not identified any case with “remotely similar facts” that would

have put them on notice that their conduct violated Griffin’s rights.

As for the Sheriff, the district court found that the “unrea-

sonable seizure” claim alleged in the amended complaint, to the

extent it was based on a “constitutional tort,” was not cognizable

under Florida law. The court rejected Griffin’s reliance on a negli-

gence theory, reasoning that it was not properly raised in the oper-

ative complaint, and that, even if it was, summary judgment was

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appropriate because the deputies took reasonable steps to protect

Griffin’s privacy in connection with the execution of the search

warrant. Griffin appeals.

III.

Qualified immunity protects government employees from

individual liability for discretionary conduct unless they violate

clearly established law of which a reasonable person would have

known. Keating v. City of Miami, 598 F.3d 753, 762 (11th Cir. 2010).

The qualified-immunity inquiry “turns on the objective legal rea-

sonableness of the action, assessed in light of the legal rules that

were clearly established at the time it was taken.” Pearson v. Calla-

han, 555 U.S. 223, 244 (2009) (quotation marks omitted).

Officials invoking qualified immunity must show first that

they were acting within the scope of their discretionary authority.

Sebastian v. Ortiz, 918 F.3d 1301, 1307 (11th Cir. 2019). There is no

dispute that Defendants Brown and Carpenter were engaged in dis-

cretionary duties on the morning of August 29, 2019. Griffin there-

fore has the burden to show that qualified immunity does not ap-

ply. See id.

To meet this burden, the plaintiff must establish that “(1) the

defendant violated a constitutional right, and (2) this right was

clearly established at the time of the alleged violation.” Miller v.

Palm Beach Cnty. Sheriff’s Office, 129 F.4th 1329, 1333 (11th Cir.

2025). Whether qualified immunity applies must be decided “on a

claim-by-claim and defendant-by-defendant basis.” Id. “The salient

question for our clearly established analysis is whether the state of

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the law at the time the officers acted gave them fair warning that

their conduct was unconstitutional.” Bates v. Harvey, 518 F.3d 1233,

1248 (11th Cir. 2008) (quotation marks omitted).

A.

When officers execute a search warrant for contraband,

“safety considerations require that they secure the premises, which

may include detaining current occupants.” Bailey v. United States,

568 U.S. 186, 195 (2013). “By taking unquestioned command of the

situation, the officers can search without fear that occupants, who

are on the premises and able to observe the course of the search,

will become disruptive, dangerous, or otherwise frustrate the

search.” Id. (quotation marks omitted). And even without evi-

dence of “a special danger to the police,” we have recognized, “ex-

ecuting the warrant may give rise to sudden violence or frantic ef-

forts to conceal or destroy evidence.” United States v. Martin, 972

F.3d 1230, 1237 (11th Cir. 2020) (quotation marks omitted).

Nevertheless, a “seizure that is lawful at its inception can vi-

olate the Fourth Amendment if its manner of execution unreason-

ably infringes interests protected by the Constitution.” Illinois v.

Caballes, 543 U.S. 405, 407 (2005); see Croom v. Balkwill, 645 F.3d

1240, 1250 (11th Cir. 2011) (“When dealing with limited seizures

not subject to the probable-cause requirement, a seizure that is rea-

sonable at its inception may quickly become unreasonable if it ex-

tends beyond its unique justification.”). That can happen when a

search or seizure is “conducted in a manner ‘unusually harmful to

an individual’s privacy or even physical interests.’” May v. City of

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Nahunta, Ga., 846 F.3d 1320, 1330 (11th Cir. 2017) (quoting Whren

v. United States, 517 U.S. 806, 818 (1996)); see Michigan v. Summers,

452 U.S. 692, 705 n.21 (1981) (stating that “special circumstances,

or possibly a prolonged detention,” may render detention during a

search unreasonable).

The essential question is whether the seizure is “objectively

reasonable” under the totality of the circumstances. See Stephens v.

DeGiovanni, 852 F.3d 1298, 1317 (11th Cir. 2017). Thus, “while de-

tentions of occupants during the period of a search will under most

circumstances prove to have been reasonable, a detention may be

unreasonable in a particular instance . . . because it is carried out in

an unreasonable manner.” Franklin v. Foxworth, 31 F.3d 873, 876

(9th Cir. 1994).

We have recognized that “people have a protected privacy

interest in avoiding . . . exposure of their naked bodies.” Padgett v.

Donald, 401 F.3d 1273, 1281 (11th Cir. 2005); see United States v.

Afanador, 567 F.2d 1325, 1331 (5th Cir. 1978) (“In a civilized society,

one’s anatomy is draped with constitutional protections.”). Be-

cause “most people have a special sense of privacy in their geni-

tals,” the “involuntary exposure of them” to others “may be espe-

cially demeaning and humiliating.” Fortner v. Thomas, 983 F.2d

1024, 1030 (11th Cir. 1993) (recognizing prisoners’ “right to bodily

privacy”). Thus, absent a legitimate reason, individuals retain the

right not to have their naked bodies involuntarily exposed. See

Padgett, 401 F.3d at 1281; Fortner, 983 F.2d at 1030.

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In Los Angeles County v. Rettele, the Supreme Court addressed

whether officers violated the Fourth Amendment when they

forced suspects to expose themselves during the execution of a

search warrant. 550 U.S. 609, 615–16 (2007). Officers entered the

plaintiffs’ home with a valid search warrant, ordered the plain-

tiffs—who were naked—out of bed, and did not allow them to “re-

trieve clothing or to cover themselves with the sheets.” 550 U.S. at

611, 615. After about two minutes, once the police were satisfied

that no immediate threat was presented, the officers allowed the

plaintiffs to dress. Id.

Because there was no evidence that the “deputies prevented

[the plaintiffs] from dressing longer than necessary to protect their

safety,” the Court held that the officers acted reasonably to protect

themselves from danger. Id. at 615–16. In other words, the Fourth

Amendment is not violated “[w]hen officers execute a valid war-

rant and act in a reasonable manner to protect themselves from

harm,” even if the officers cause real “frustration, embarrassment,

and humiliation” to innocent occupants in the process. See id.

In May, an officer responding to assist EMTs on a 911 call

detained a woman in a locked room for twenty minutes and forced

her to disrobe and change before transport for a psychological eval-

uation. 846 F.3d at 1331. The officer refused her requests to leave,

failed to ask a female EMT to remain with her instead, and even

“used the threat of deadly force to compel her to remove her

shorts, in order to first put on undergarments, by patting his gun

after she initially refused.” Id. The officer claimed that his actions

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were justified to have the woman, who was wearing a nightgown,

put on more appropriate clothing for transport, and to prevent self-

harm. Id.

We held that, while the initial seizure was supported by ar-

guable probable cause, questions of fact existed “with respect to

whether the seizure was conducted in an extraordinary manner,

unusually harmful to [the plaintiff’s] privacy interests.” Id. at 1329.

We explained that an “initially constitutional seizure can become

unconstitutional where it is executed in an extraordinary manner.”

Id. at 1330. “Balancing the government interest” in safety and pre-

vention of self-harm against the plaintiff’s “interest in bodily sanc-

tity and personal security,” we concluded that the officer’s conduct

“exceeded the scope of the underlying justification and that he

failed to use reasonable means to rectify the situation.” Id. We

reasoned that the officer’s “patent disregard for [the plaintiff’s] per-

sonal dignity” over a “prolonged duration” was sufficient to violate

the Fourth Amendment. Id.

We also held that the officer was not entitled to qualified

immunity. Id. at 1332. We reasoned that it would have been ob-

vious to any reasonable officer that he could not engage in “degrad-

ing and humiliating methods” to conduct a seizure, such as using

the “threat of deadly force to compel a female civilian to disrobe”

for transport for a psychological evaluation. Id. That conduct, we

observed, was “representative of the type of unnecessarily invasive

and demeaning intrusion that is undoubtedly within the sphere of

what the Fourth Amendment prohibits.” Id. Given the officer’s

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“disregard for [the plaintiff’s] privacy, his use of forcible language

coupled with the threat of deadly force, the prolonged duration of

the seizure, and the inappropriateness inherent in the circum-

stances,” we concluded that the manner of seizure went “well be-

yond the hazy border that sometimes separates lawful conduct

from unlawful conduct.” Id. (quoting Evans v. Stephens, 407 F.3d

1272, 1283 (11th Cir. 2005) (en banc)).

B.

Here, we conclude that genuine issues of material fact re-

main as to whether Griffin suffered a constitutional violation on

August 29, 2019. Before explaining why, we start with a few points

of clarification.

In executing the search warrant, the validity of which Griffin

does not dispute, the deputies were permitted to detain the occu-

pants of the residence, including Griffin and her children, while

they secured the premises. See Bailey, 568 U.S. at 195; Martin, 972

F.3d at 1237. The fact that Griffin was naked when they arrived did

not prevent the officers from acting to protect themselves and the

occupants and to prevent destruction of evidence by ordering the

occupants to leave the premises, even if it resulted in “frustration,

embarrassment, and humiliation” to an innocent occupant like

Griffin. See Rettele, 550 U.S. at 615–16. Thus, the question is

whether, under the totality of the circumstances, Griffin’s “right to

personal security was unreasonably violated by [the deputies’] ac-

tions following the initial seizure.” May, 846 F.3d at 1330.

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Construing the evidence and drawing all reasonable infer-

ences, genuine issues of material fact remain as to whether the

“deputies prevented [Griffin] from dressing longer than necessary”

for safety or investigatory reasons. Rettele, 550 U.S. at 615–16. Usu-

ally, the “slight” nature of the “additional intrusion caused by de-

tention” is reasonable “because the justifications for detention are

substantial.” Bailey, 568 U.S. at 193 (quotation marks omitted). But

the circumstances of Griffin’s detention were far more intrusive

than usual. And the evidence, construed in Griffin’s favor, supports

a finding that she was detained in unusually demeaning conditions

for longer than reasonably justified by safety or investigatory rea-

sons. See Rettele, 550 U.S. at 615–16.

Griffin was prevented from dressing for nearly 40 minutes.2

That’s a long time to be detained nude, mostly outside the home

and in a semi-public setting. While it was dark at the outset of the

seizure, and the deputies took some steps to mitigate Griffin’s nu-

dity, both Griffin and her son testified that the rain jacket was too

small, too short, and did not cover Griffin’s genitalia or buttocks,

even if it was capable of adequately covering her breasts if held

2 Defendants claim that “[a]pproximately 34 minutes elapsed between the time

Griffin exited her residence, officers secured Streeter, and she was able to

dress.” Construing the evidence in the light most favorable to Griffin, how-

ever, she left her home at approximately 5:47 a.m., and was not permitted to

dress until around 6:26 a.m., for a total of nearly 40 minutes. But even if De-

fendants can prove at trial that it was 34 minutes, genuine issues of material

fact still would remain as to whether the “deputies prevented [Griffin] from

dressing longer than necessary” for safety or investigatory reasons. Rettele, 550

U.S. at 615–16.

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closed. 3 Moreover, it appears to have become light outside while

Griffin was in the patrol car with her two children. The evidence

also shows that Griffin was not wearing the jacket for part of that

time. So she remained fully naked and visible to her own children

in the car—including one of the opposite sex—as well as nearby

deputies through the car’s windows.

A reasonable jury could also conclude that “less intrusive

means were practically available to accomplish the objective of the

seizure.” May, 846 F.3d at 1330 n.6 (“The question of reasonable-

ness may sometimes turn on whether less intrusive means were

practically available to accomplish the objective of the seizure, as

in the context of an unduly intrusive search or an extended deten-

tion.”). No evidence was presented to show why Griffin could not

have received a more adequate covering, or even the fitted sheet

she eventually received, while she was inside the patrol car.

Defendants argue that the delay was necessary for safety rea-

sons due to Streeter’s failure to comply. But a reasonable jury

could conclude otherwise. Approximately fifteen law enforce-

ments officers were on scene, several of whom were not directly

involved in securing Streeter. And it appears officers had swept the

3 Contrary to the district court, we see nothing in the body-camera footage

that directly or obviously contradicts the testimony on these points, such that

no reasonable jury could credit it, even assuming the court is correct that Grif-

fin’s breasts were adequately covered. See Feliciano v. City of Miami Beach, 707

F.3d 1244, 1253–54 (11th Cir. 2013) (stating that “a plaintiff’s testimony cannot

be discounted on summary judgment unless it is blatantly contradicted by the

record,” including video evidence).

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rest of the house before encountering Streeter in his bedroom. In

any event, Streeter was in custody by approximately 6:07 a.m.,

more than ten minutes before Griffin received any covering for her

genitalia or buttocks. Construed in Griffin’s favor, this evidence

supports a reasonable inference that Griffin was prevented from

covering her naked intimate parts for “longer than necessary.”4 See

Rettele, 550 U.S. at 615–16.

Based on the totality of the circumstances, as construed in

favor of Griffin, the nonmoving party, a reasonable jury could con-

clude that deputies violated her Fourth Amendment right to per-

sonal privacy during the execution of the search warrant on August

29, 2019.

C.

We now turn to the question of whether Defendants Brown

and Carpenter are entitled to qualified immunity for their conduct.

Whether qualified immunity applies must be decided “on a claim-

by-claim and defendant-by-defendant basis.” Miller, 129 F.4th at

1333. The unlawfulness of each defendant’s conduct must have

been “clearly established at the time” it occurred. Pearson, 555 U.S.

at 244.

4 Nor is it clear why Griffin could not have been permitted to dress immedi-

ately upon her return to the home. The only justification offered was the

reading of the search warrant. But there’s no evidence that safety or investi-

gatory considerations would change if Griffin had been permitted to dress be-

fore the reading of the warrant, rather than after, because the residence was

secured by that point.

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“To be clearly established, a right must be well-established

enough that every reasonable official would have understood that

what he is doing violates that right.” Gates v. Khokhar, 884 F.3d

1290, 1296 (11th Cir. 2018) (quotation marks omitted). In other

words, officers are entitled to “fair warning that their conduct was

unconstitutional.” Bates, 518 F.3d at 1248. If the reasonableness of

the officers’ conduct is “arguable,” qualified immunity likely ap-

plies. See, e.g., Jackson v. Sauls, 206 F.3d 1156, 1165 (11th Cir. 2000)

(“When an officer asserts qualified immunity, the issue is not

whether reasonable suspicion existed in fact, but whether the of-

ficer had ‘arguable’ reasonable suspicion to support an investiga-

tory stop.”).

1. Defendant Brown

As the district court explained, Brown’s conduct with re-

spect to Griffin was fairly limited. Although he prepared the search

warrant, planned the search, and saw Griffin nude at the outset of

the encounter, the initial detention of Griffin was lawful, as we ex-

plained above. And there is no evidence that Brown was involved

in her detention until she returned to the home and he read her the

search warrant. At that point, as the district court explained,

Brown was inside her home (not outside), and she had a fitted sheet

wrapped around her body. So she was no longer forced to expose

her naked body, even if the circumstances of her detention re-

mained more intrusive than usual. We cannot say Brown had fair

notice it was unlawful to detain Griffin in the bedsheet briefly while

reading the search warrant, before allowing her to dress.

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That Brown prepared the search warrant does not make him

liable for all unreasonable conduct during the search. The circum-

stances here are not like a facially deficient search warrant, where

it makes sense to hold the officer who prepared the deficient war-

rant responsible. See Groh v. Ramirez, 540 U.S. 551, 563–66 (2004).

Nor is this case anything like Amaechi v. West, 237 F.3d 356, 359–60

(4th Cir. 2001), where an officer conducted a “sexually intrusive

search”—touching and penetrating an arrestee’s vagina—incident

to arrest for violating a noise ordinance. Accordingly, we agree

with the district court that Brown is entitled to qualified immunity.

2. Defendant Carpenter

Griffin’s claim against Carpenter is for supervisory liability

under § 1983. “Supervisors can be held personally liable when ei-

ther (1) the supervisor personally participates in the alleged consti-

tutional violation, or (2) there is a causal connection between the

actions of the supervisor and the alleged constitutional violation.”

Mann v. Taser Int’l, Inc., 588 F.3d 1291, 1308 (11th Cir. 2009). The

plaintiff also must establish a constitutional violation. Id.

Here, a reasonable jury could conclude that Griffin satisfied

the elements of supervisory liability. See id. In the light most fa-

vorable to Griffin, the record shows that Carpenter, in contrast to

Brown, maintained control over and responsibility for Griffin’s de-

tention. He was personally involved in procuring the jacket for

Griffin, he interacted with her while she was in the patrol car at the

plaza, and he oversaw her transfer from the patrol car to the resi-

dence with the fitted bedsheet as covering. And for the reasons we

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18 Opinion of the Court 25-10929

have already explained, a reasonable jury could conclude that Grif-

fin’s right to personal privacy was violated during the execution of

the search warrant on August 29, 2019.

Still, it’s not enough “to demonstrate that a genuine issue of

fact exists on the merits of her claim.” Keith v. DeKalb County, 749

F.3d 1034, 1048 (11th Cir. 2014). Rather, Griffin must also over-

come Carpenter’s assertion of qualified immunity by showing that

the unlawfulness of the conduct was “clearly established at the time

[Carpenter] acted.” Id. (quotation marks omitted). “The notice

must be clear to every reasonable official, and it must place the law

beyond debate.” Hughes v. Locure, 166 F.4th 121, 128 (11th Cir.

2026) (quotation marks omitted). We think that’s the case here.

The Supreme Court’s decision in Rettele established that po-

lice officers violate the Fourth Amendment when they force an ar-

restee to expose herself “longer than necessary to protect their

safety” or to effectuate some other legitimate purpose. 550 U.S. at

615. Rettele and our decision in May also established that unneces-

sary involuntary exposure to officers, even in a private setting, vio-

lates the Fourth Amendment, and that “patent disregard for [a

plaintiff’s] personal dignity” over a “prolonged duration” is unlaw-

ful. Id.; May, 846 F.3d at 1330–31 (holding that an officer violated

the Fourth Amendment by detaining a woman in her bedroom and

forcing her to disrobe and change before transport).

Here, unlike in Rettele, where the involuntary nudity was

constitutional because it was brief and lasted no longer than neces-

sary to protect the officers’ safety, Griffin’s involuntary exposure

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continued for longer than necessary, with no good law-enforce-

ment purpose. In the light most favorable to Griffin, a reasonable

jury could conclude that, even though her nude detention may

have been justified at the outset, Carpenter and deputies under his

supervision forced her to expose her intimate parts against her will

to her children and deputies on scene, if not the public more gen-

erally, for at least ten minutes without any legitimate law-enforce-

ment purpose. Accordingly, we find it was clearly established at

the time of the incident in question that Griffin had a broad consti-

tutional right to bodily privacy, and that in the light most favorable

to her, a reasonable jury could find that Defendant Carpenter vio-

lated that right.

D.

Finally, we consider Griffin’s claim against the Sheriff under

Fla. Stat. § 768.28. The district court granted summary judgment

on this claim for three reasons: (1) Griffin could not bring a consti-

tutional claim under § 768.28; (2) Griffin failed to assert a negli-

gence claim in her complaint; and (3) even if a negligence claim was

asserted, no “reasonable jury could find that the deputies breached

any duty of care owed to [Griffin].” Griffin does not dispute the

first determination, but she argues that she adequately pled a neg-

ligence claim and that the evidence was sufficient to prove the ele-

ments of negligence.

We vacate the grant of summary judgment to the Sheriff

and remand for further proceedings. For the reasons we have al-

ready explained, a reasonable jury could find that the deputies

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20 Opinion of the Court 25-10929

breached a duty of care owed to Griffin by forcing her to expose

her intimate parts for longer than reasonably necessary under the

circumstances. See, e.g., Kaisner v. Kolb, 543 So.2d 732, 734 (Fla.

1989) (“So long as petitioner was placed in some sort of ‘custody’

or detention, he is owed a common law duty of care.”). Since the

district court did not go further, we do not otherwise address

whether the evidence is sufficient to prevail on a negligence theory.

We also agree with Griffin that the district court erred in re-

fusing to consider a negligence theory for failure to raise that claim

in the amended complaint. All that is required under the federal

pleading rules is “a short and plain statement of the claim,” Fed. R.

Civ. P. (a), which “give[s] the defendant fair notice of what the

plaintiff’s claim is and the grounds upon which it rests,” Erickson v.

Pardus, 551 U.S. 89, 93 (2007) (cleaned up). “[T]he federal notice

pleading standard only requires allegations as to every material

point necessary to sustain a claim on any legal theory, even if it is

not the precise theory advanced by the plaintiff.” Ray v. Comm’r,

Ala. Dep’t of Corr., 915 F.3d 689, 697 n.3 (11th Cir. 2019).

Thus, the amended complaint need not have used specific

terminology or identified the “precise theory” under which Griffin

intended to prevail on her § 768.28 claim against the Sheriff. And

the pleading otherwise alleged that, while detaining her in the exe-

cution of their duties, the deputies on scene forced her to expose

her nude body in an unreasonable manner, causing her injury. Ac-

cordingly, we conclude that Griffin did not present a new claim at

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25-10929 Opinion of the Court 21

summary judgment by attempting to proceed on a negligence the-

ory against the Sheriff.

IV.

In sum, we affirm the grant of qualified immunity to De-

fendant Brown. We vacate the grant of qualified immunity to De-

fendant Carpenter, as well as the grant of summary judgment to

Sheriff Aden. We remand for further proceedings consistent with

this opinion.

AFFIRMED in part; VACATED in part; and REMANDED

for further proceedings.