24.  Plaintiffs bring this class action pursuant to Rules 23(a) and (b)(2)  and/or (b)(3) of the Federal Rules of Civil Procedure on their behalf and on behalf  of a class similarly situated and affected during the pendency of this lawsuit and in  the future.  Plaintiffs will seek to certify a class to seek relief with respect to the  Unsanctioned and Forced Drug Tests Policy.  The class is defined as all persons  with criminal charges requiring them to appear in the White County Probate Court  who are, were, or in the future will be subject to the Defendants’ practice of  requiring probationers to submit to and to pay for drug tests, in the absence of any  court order authorizing such drug tests.       25.  Plaintiffs meet the requirements of Rule 23(a) in that:    a. The class is so numerous that joinder of all members is impracticable.   The class consists of an unknown number of probationers, who can be  readily identified through court and probation records, who have been  9  or will be under a legal obligation to appear before the White County  Probate Court, and who are subject to Defendants’ policy of requiring  submission to and payment for drug tests in cases in which no such  tests were court-ordered.      b. There are questions of law and fact common to the class concerning  the constitutionality and lawfulness of the Defendants’ policy  challenged in this Complaint.  The absence of any lawful basis for  forcing probationers to submit their urine and to pay for drug tests  presents a question of fact and law common to all class members.   Similarly, there is a common question as to whether the Unsanctioned  and Forced Drug Tests Policy violates state and federal law.   c. The policy challenged in this action applies with equal force to the  named plaintiffs and all members of the class so that the claims of the  plaintiffs are typical of those of the class.  Ligocki and Luse were  subject to the Unsanctioned and Forced Drug Tests Policy.      d. The named Plaintiffs will fairly and adequately protect the interests of  the class.  The Plaintiffs possess the requisite personal interest in the  subject matter of the lawsuit and possess no interests adverse to other  class members.  The Plaintiffs are represented by attorneys at the  10  Southern Center for Human Rights, a nonprofit organization with  extensive experience in complex class action litigation.     26.  Plaintiffs meet the requirements of Rule 23(b)(2) in that the  Defendants acted or refused to act on grounds that apply generally to the class, so  that final injunctive relief or corresponding declaratory relief is appropriate  respecting the class as a whole.   27.  Plaintiffs meet the requirements of Rule 23(b)(3) because common  questions of law and fact predominate over questions affecting individual class  members.  A class action is superior to any other method of adjudicating this  dispute because hundreds of people are subjected to the Unsanctioned and Forced  Drug Tests Policy described in this Complaint, but few are likely to have the time,  legal acumen, and resources to pursue the claims at issue in this case on their own.  28.  The Georgia Code authorizes governing authorities to contract with  private companies to provide probation supervision services.  O.C.G.A. § 42-8- 101(a)(1).  The White County Probate Court, with the approval of the government  of White County, entered into such a contract with Sentinel.  (Exhibit A.)  11  B. Sentinel’s Violation of Its Contract with White County and of Georgia  Rules and Regulations Governing Fee Collection     29.  The contract between the White County Probate Court and Sentinel  states that Sentinel agrees to “[c]ollect from probationers, court-ordered fines,  restitution and other costs associated with order of the Court.” Exhibit A at 2  (emphasis supplied).  The contract further provides that “[d]rug counselling and  urine surveillance will be provided to probationers identified by the Court has  having drug or alcohol related problems.  Probationers will assume the cost of  random drug and/or alcohol testing.”  Id. at 3 (emphasis supplied).   30.  The Rules and Regulations of the State of Georgia place further  limitations on the circumstances under which probation companies may assess  fees.  Ga. Comp. R. & Regs. 503-1-.30 states:  a. No probation entity shall assess, collect, or disburse any funds as it  pertains to the collection of court-ordered monies, except by written  order of the court or as required by State law.   b. No probation entity, owner, director, agent, or employee may offer  any program service or component for an additional fee unless the fee  charge has been ordered by the court or as required by State law.   31.  Ga. Comp. R. & Regs. 503-1-.31 further states: “No owner, operator,  director, agent or employee shall collect or disburse any funds as it pertains to  12  O.C.G.A. § 42-8-100, except by written or oral order of the court or as required by  State law.”   32.  Defendants’ practice of drug-testing Plaintiffs and charging them  money for such tests violates both Sentinel’s contract with the Probate Court and  Rules and Regulations of the State of Georgia governing private probation entities.   C. Application of Defendants’ Policies to Rita Sanders Luse   33.  On March 12, 2014, Luse appeared in the White County Probate  Court and pleaded guilty to the charge of driving while unlicensed.1     34.  The Probate Court sentenced Luse to pay a fine of $775.75.  Because  Luse could not pay on the day of court, Judge Baker placed Luse on probation for  12 months and ordered her to pay $44 per month in probation supervision fees.      35.  Judge Baker memorialized Luse’s sentence in a disposition form.   (Exhibit B.)  The disposition form contains a number of boxes that the judge can  check if he wishes to impose special conditions of probation.  The policy and  practice of the Probate Court, consistent with Georgia law and the Constitution, is  1 Unbeknownst to her, Luse’s license had been suspended due to a then-unresolved  citation involving Luse’s car registration.      13  to write all court-imposed obligations on the disposition sheet so that probationers  understand what is required of them.       36.  The disposition form in Luse’s case shows that no special conditions  of probation were imposed.  In particular, Judge Baker did not impose the special  condition printed on the form that states: “Probationer shall upon request by the  Probation Officer or any Law Enforcement Officer, produce specimen of bodily  substance for analysis for the presence of a substance prohibited by the Law of the  State of Georgia, the United States or by the terms of this sentence.”  (Exhibit B.)        37.  Although the court did not order drug-testing in Luse’s case, Sentinel  drug-tested her anyway.  When Luse reported to Sentinel’s Cleveland office,  Defendant McDowell-Black told Luse that she would be required to take a drug  test.  Luse objected.  McDowell-Black falsely told Luse that drug testing was a  condition of her probation and that she was required to submit a urine sample.       38.  McDowell-Black required Luse to sign a document that would purport  to permit Sentinel to collect and test Luse’s urine for controlled substances.  Luse  signed the document, believing, due to McDowell-Black’s misrepresentation, that  her probation could be revoked if she refused to comply with her probation  officer’s directions.   14   39.  Luse was then instructed to urinate in a cup and to deliver her urine  specimen to a Sentinel employee.   40.  Sentinel charged Luse a $15 fee for each drug test.   41.  McDowell-Black repeatedly caused Luse to submit to and pay for  drug tests over the course of her year on probation.   42.  Luse never tested positive for any controlled substance.   43.  Luse does not drink any alcohol or use illegal drugs.  During the  course of her probation sentence, Luse never manifested any signs or symptoms of  a person under the influence of or dependent on drugs or alcohol.   44.  McDowell-Black further falsely threatened to immediately jail Luse  when Luse was unable to pay her fines and fees.   45.  About halfway through her probation term, Luse reported to  McDowell-Black without her payment.  Luse explained that she did not have any  money left in her bank account, but that she would receive a pay check from her  employer in a few days.  Luse asked for a brief extension on Sentinel’s payment  deadline.  McDowell-Black falsely informed Luse that if she did not have her full  payment of approximately $140 within a few hours, McDowell-Black would have  Luse immediately arrested.      15   46.  Luse was forced to call a relative to ask for a loan, to rush across town  to collect the loaned money, to obtain a money order, and to rush back to  Sentinel’s office with the payment.  She did so believing that she would be sent to  jail if she did not pay that day.     47.  McDowell-Black’s use of the false threat of imminent jail to coerce an  immediate payment from Luse caused Luse anxiety, stress, and humiliation.  D. Application of Defendants’ Policies to Marianne Ligocki   48.  On February 10, 2015, Ligocki was on her way to pick up her son  from school when a White County Sheriff’s Deputy stopped her vehicle at a  roadside checkpoint.  The deputy discovered that Ligocki’s driver’s license was  suspended,2 and he cited her for driving on a suspended license.     49.  On July 8, 2015, Ligocki appeared in the White County Probate Court  and pleaded guilty to a reduced charge of driving while unlicensed.       50.  Judge Baker sentenced Ligocki to a fine and surcharges totaling  $313.02.  Because Ligocki was unable to pay the fine on the day of court, Judge  2 Ligocki’s license was suspended due to a traffic ticket from the DeKalb County  Recorder’s Court from 2011.  Ligocki believed that she had paid the Recorder’s  Court ticket and that the case had been resolved.  Following her arrest in White  County, Ligocki resolved the DeKalb County Recorder’s Court ticket and had her  license reinstated.   16  Baker sentenced her to 12 months on probation at $44.00 per month.  Judge Baker  also sentenced Ligocki to 20 hours of community service, to be suspended upon  payment of all fines and surcharges.           51.  Judge Baker memorialized Ligocki’s sentence in a disposition form.   (Exhibit C.)  The disposition form contains a number of boxes that the judge could  check if he wished to impose special conditions of probation.     52.  The disposition form in Ligocki’s case shows that no special  conditions of probation were imposed.  In particular, Judge Baker did not impose  the condition printed on the form that states: “Probationer shall upon request by the  Probation Officer or any Law Enforcement Officer, produce specimen of bodily  substance for analysis for the presence of a substance prohibited by the Law of the  State of Georgia, the United States or by the terms of this sentence.”  (Exhibit C.)        53.  On July 23, 2015, Ligocki reported for her first visit to McDowell- Black at Sentinel’s Cleveland office.  Upon arrival, Ligocki was required to submit  to a pat-down search of her person by a Sentinel employee.     54.  McDowell-Black then told Ligocki that Ligocki would be required to  submit a urine sample for a drug test.  Ligocki objected, pointing out that the  Probate Court had not ordered drug testing in her case.  17   55.  McDowell-Black falsely told Ligocki that drug testing was a  condition of her probation and that she was required to submit a urine sample.     56.  McDowell-Black forced Ligocki to sign a “waiver” document that  purported to permit Sentinel to test Ligocki’s urine for drugs.  Ligocki protested  again and asked what would happen if she did not sign the “waiver” document.   McDowell-Black falsely responded that if Ligocki did not sign the document she  could not be on probation and her probation could be revoked.  Ligocki signed the  document, believing, due to McDowell-Black’s misrepresentation, that she could  be sent to jail if she refused to comply with her probation officer’s directions.    57.  McDowell-Black then instructed Ligocki to submit a urine sample.   Ligocki was required to take down her pants and urinate in a cup with the door  partially open and with a Sentinel employee standing by the door to the bathroom.   McDowell-Black alleged that she tested positive for THC.   58.  Ligocki was subsequently drug-tested repeatedly over the course of  her probation.  Each time, she was required to urinate with the door open and with  a Sentinel employee standing at the door.  Sentinel charged Ligocki a fee for each  drug test.   59.  On September 17, 2015, McDowell-Black alleged that Ligocki’s drug  test was positive for THC.  18   60.  McDowell-Black told Ligocki that she was “violating” her.   McDowell-Black told Ligocki that she would be required to perform 30 hours of  community service or bring Sentinel $217.50 in 30 days.  McDowell-Black also  told Ligocki that she would be required to take and pay for additional monthly  drug tests for the next six months, and that she would not be eligible for early  termination of probation.  Ligocki completed the community service.     61.  On December 4, 2015, Ligocki reported for a pre-scheduled probation  appointment and submitted her required payment.  At this appointment,  McDowell-Black instructed Ligocki to return to the Sentinel office for another  drug test on December 10, 2015.  Ligocki did so.   62.  On December 10, 2015, Ligocki appeared at the Sentinel office and  McDowell-Black instructed her to submit to a drug test.  On this occasion, Ligocki  was required to urinate in a cup while the bathroom door was wide open, and with  a Sentinel employee watching her urinate.     63.  Following the December 10 drug test, McDowell-Black claimed that  Ligocki had again tested positive for THC.  The drug test result was in error  because Ligocki had not used marijuana.  Ligocki objected that the test result was  erroneous.  19   64.  McDowell-Black called Ligocki a “liar,” told her she was going to  issue a warrant for Ligocki’s arrest, and instructed her to immediately leave her  office.  McDowell-Black told Ligocki “I’ll see you in jail.”   65.  Since December 2015, Ligocki has experienced stress and anxiety  from the fear that she could be imminently arrested in connection with drug tests  that no court ordered her to take.   66.  To date, Sentinel has collected far more money for itself than it has  allocated to the fine imposed in Ligocki’s case.  The following chart shows  Ligocki’s payments and the manner in which Sentinel has distributed them:    Date  Fine  Sentinel’s  Drug Test Fee  Sentinel’s  Probation  Supervision Fee  Ga. Crime  Victim  Emergency  Fund  Ligocki’s  Total  Payment  July 23, 2015  $41   $15   $35   $9   $100   August 19, 2015  $34   $35   $9  $78   September 17, 2015 $19   $15   $35   $9   $78   October 26, 2015  $4   $30   $34   October 26, 2015  $35   $35   October 26, 2015  $9   $9   November 16, 2015    $24   $24   November 16, 2015    $15   $15   December 4, 2015  $33   $20   $53   December 4, 2015  $46   $46   December 4, 2015  $18   $18   Total Paid  $131  $95   $210   $54  $490   20   67.  To date, Ligocki has paid $490 in connection with her citation for  driving while unlicensed.  Only $131 of that amount has been applied to her fine.   By contrast, Sentinel collected $305 for itself.    68.  To date, Ligocki has submitted to drug screens on five occasions.  She  has paid Sentinel $95 in drug test fees that were never ordered by any court.  69.  Plaintiffs incorporate herein and re-allege, as if fully set forth herein,  all factual allegations of paragraphs 1-17, 22-23, and 28-68.    70.  Without probable cause or legal authority, Defendants required  Plaintiffs and other probationers to submit their urine to Sentinel employees and to  pay for drug tests not ordered by any court.  They did so for the purpose of  generating revenue for their company.  21   71.  Defendants required Plaintiffs to submit to drug tests even though  they had no basis to believe that either Plaintiff had committed or was committing  any criminal offense or violation.   72.  Defendants required probationers to take drug tests at their own  expense without any involvement of a court or objective standards governing when  or how often this invasive procedure would occur.   73.  The search of each Plaintiff’s urine was unreasonable under the  Fourth and Fourteenth Amendments to the United States Constitution and under  Ga. Const. art. I, sec. I, para. XIII.     74.  The urine tests administered to Plaintiffs constituted a search for  which judicial oversight was required.  There was no such oversight permitting  such an intrusive search in Plaintiffs’ cases.   75.  The Defendants had fair warning that their conduct would violate the  Constitution and no reasonable officer or probation officer could have believed that  requiring Plaintiffs to submit to these drug tests was legal.   76.  In each and every instance set forth above, Defendants acted  intentionally, with malice, and with actual intent to cause injury in the performance  of their official functions.  Defendants knew or should have known that requiring  22  Plaintiffs to submit to drug tests, without any legal authority, violated Plaintiffs’  constitutional rights.     77.  As a direct and proximate result of Defendants’ illegal policies and  practices, Defendants searched Plaintiffs’ urine in violation of law.  Defendants are  jointly and severally liable for the violations of Plaintiffs’ rights, and the harm they  suffered as a result, because each Defendant either personally participated in the  actions or failures to act, or implicitly authorized, approved, or knowingly  condoned or failed to remedy the wrongs at issue.   78.  Defendants’ above-described actions were willful, deliberate, and  malicious, and involved reckless or callous indifference to Plaintiffs’ rights and  should be punished and deterred by an award of punitive or enhanced damages  against Defendants as permitted by law.   79.  Plaintiffs incorporate herein and re-allege, as if fully set forth herein,  all factual allegations of paragraphs 1-17, 22-23, and 28-68.    23   80.  Defendants drug-tested Plaintiffs and other probationers without  notice to the probationers that they would be required to submit to drug tests, and  without any process available to challenge the legality of such tests.  By drug- testing Plaintiffs without notice or legal authority to collect their urine samples and  by requiring Plaintiffs to pay for such testing, Defendants deprived Plaintiffs of  their privacy interests and property without due process of law in violation of  Plaintiffs’ rights.  U.S. Const. amend. XIV; Ga. Const. art. 1, § I, ¶¶ I and II.   81.  Defendants jointly and severally caused deprivations of Plaintiffs’  privacy interests and money, under color of law, without providing notice or an  opportunity to be heard.  In addition, Defendants jointly and severally caused  deprivations of Plaintiffs’ substantive due process rights through their deliberate  indifference to Plaintiffs’ right to privacy and their conscience-shocking treatment  of people under their control.    82.  Defendants further violated Luse’s due process rights when  McDowell-Black falsely told Luse, who had no money, that she would have to pay  $140 within a few hours or be immediately jailed.  Certainly, Luse was under an  obligation to pay court-ordered monies.  However, Georgia law provides that “the  imposition of sanctions for failure to pay [monies assessed by the court] shall be  within the discretion of the court through judicial process or hearings.”  O.C.G.A. §  24  42-8-102(e)(2).  Sentinel violates probationers’ due process rights when it demands  and collects the probationers’ last dollar (or, in Luse’s case, borrowed money),  under threat of immediate incarceration, without judicial process.    83.  Defendants knew or should have known that the conduct described  herein violated Plaintiffs’ rights.  Defendants’ above-described actions were  willful, deliberate, and malicious, and involved reckless or callous indifference to  Plaintiffs’ rights and should be punished and deterred by an award of punitive or  enhanced damages against individual Defendants as permitted by law.  84.  Plaintiffs incorporate herein and re-allege, as if fully set forth herein,  all factual allegations of paragraphs 1-17, 22-23, and 28-68.    85.  An action for money had and received is founded upon the equitable  principle that no one ought to unjustly enrich himself at the expense of another,  and is maintainable in all cases where one has received money under such  circumstances that in equity and good conscience he ought not to retain it.    25   86.  A cause of action based on the theory of money had and received may  be brought against a private probation company to recover probation fees which it  unlawfully collected from misdemeanor probationers in contravention of law.       87.  Defendants placed themselves in the position of receiving and  retaining money from the Plaintiffs which the Plaintiffs were not lawfully required  to pay and which Sentinel was not lawfully entitled to receive.  88.  Plaintiffs incorporate herein and re-allege, as if fully set forth herein,  all factual allegations of paragraphs 1-17, 22-23, and 28-68.    89.  Defendants’ practice of appropriating Plaintiffs’ and others’ money  without legal authority constitutes conversion – an intentional tort under Georgia  law.  See O.C.G.A. § 51-10-1 (“The owner of personalty is entitled to its  possession.  Any deprivation of such possession is a tort for which an action lies.”).  26   90.  Defendants took and converted to their own use the funds set forth  above from Plaintiffs.  Plaintiffs are entitled to recover the amount of money  converted, plus interest from the date of the conversion.   91.  Defendants’ above-described actions were willful, deliberate, and  malicious and should be punished and deterred by an award of punitive damages as  permitted by law and in an amount to be determined at trial.  92.  Plaintiffs incorporate herein and re-allege, as if fully set forth herein,  all factual allegations of paragraphs 1-17, 22-23, and 28-68.   93.  Defendants committed the tort of fraud against Plaintiffs.  The tort of  fraud has five elements: false representation, scienter, inducement, reliance, and  injury.     94.  McDowell-Black made a series of false, verbal representations to both  Plaintiffs that they were required to submit to and to pay for drug tests.   McDowell-Black knew when making this false representation to Plaintiffs that  Sentinel had no legal authority to require drug tests in these cases.  Sentinel,  27  through McDowell-Black, nonetheless induced Plaintiffs to submit to drug tests  and to pay for them.  Defendants undertook these acts with malice and intent to  deceive Plaintiffs.  McDowell-Black further made a false representation to Plaintiff  Luse that if Luse was unable to pay, she would be jailed immediately at the sole  discretion of her probation officer.       95.  Plaintiffs Luse and Ligocki relied on Defendant McDowell-Black’s  false representations regarding drug-testing and, as a proximate result of the false  representations, Plaintiffs submitted their urine to Sentinel and paid Sentinel drug  testing fees.  Plaintiff Luse relied on McDowell-Black’s false threats that Luse  would be jailed immediately at the sole discretion of McDowell-Black if she failed  to pay Sentinel on the day her payment was demanded.     96.  Plaintiffs were injured by their reliance on McDowell-Black’s false  representations regarding drug testing because they were required to submit to  repeated and intrusive searches and paid money they did not owe.  Luse was  further injured by her reliance on McDowell-Black’s false threats that Luse would  be jailed immediately, at her probation officer’s sole discretion, if she could not  pay in accordance with Sentinel’s payment deadline.  Luse suffered worry, anxiety,  and humiliation as a consequence of her probation officer’s false statements.   28  97.  Plaintiffs incorporate herein and re-allege, as if fully set forth herein,  all factual allegations of paragraphs 1-17, 22-23, and 28-68.   98.  Tortious coercion occurs when a threat coupled with an apparent  intention and ability to carry out the threat coerces action or inaction contrary to  the victim’s will.  See Peavy v. Bank South, N.A., 474 S.E.2d 690, 693, 222 Ga.  App. 501, 503 (1996); Restatement (Second) of Torts § 871 cmt. f (1979).   99.  McDowell-Black threatened Plaintiffs with probation revocation if  they failed to submit to and to pay for drug tests.  McDowell-Black had no legal  authority to require drug tests in these cases and thus no lawful basis for her  threats.    100. McDowell-Black further threatened to jail Luse if Luse was unable to  pay her fines and fees, contrary to established law holding that a person may not be  jailed solely for inability to make a payment.  101. McDowell-Black had the apparent intent and ability to carry out her  threats through her role as a private probation officer for Sentinel.    29  102. Plaintiffs unwillingly provided urine samples and unwillingly paid  money as a result of McDowell-Black’s threats.  103. Plaintiffs were injured because they were required to submit to  repeated, intrusive searches and repeatedly paid money they did not owe.    104. Plaintiff Luse was further injured by her submission to McDowell- Black’s threats to jail Luse if she could not pay.  Luse suffered worry, stress,  anxiety, and humiliation as a consequence of her probation officer’s threats.  A. The White County Probate Court’s Delegation of Probation Services to  Sentinel    Conversion  O.C.G.A. § 51-10-1  (by all Plaintiff against all Defendants)   Declaratory Relief  (By Plaintiff Ligocki Against Defendants)  114. Plaintiffs incorporate herein and re-allege, as if fully set forth herein,  all factual allegations of paragraphs 1-17, 22-23, and 28-68..  115. Ligocki is still on probation and is under the supervision of  McDowell-Black and Sentinel.  116. Without legal authority, Defendants forced Ligocki and other  probationers to submit to drug tests and to pay for drug tests that were never  ordered by any court.  McDowell-Black further has a practice of coercing  32  payments by using false threats that nonpayment will automatically result in  immediate incarceration in the sole discretion of the probation officer.      117. Pursuant to 28 U.S.C. § 2201, Ligocki seeks a declaration by the  Court that Defendants may not require probationers to submit to drug test that have  not been ordered by any court.  Plaintiff further seeks a declaration by the Court  that Sentinel probation officers may not coerce payments from probationers by  employing false threats that nonpayment will result in immediate jail in the sole  discretion of the probation officer.      118. Plaintiffs and putative class members will be adversely affected if  Defendants continue to drug-test people in cases in which no drug testing has been  ordered by the court.  Ligocki and others will be adversely affected if Defendants  continue to coerce payments through false threats that nonpayment will result in  immediate incarceration in the sole discretion of the probation officer.   Due Process Clause Violations  Violation of the Fourteenth Amendment to the United States Constitution,  Brought Under 42 U.S.C. § 1983, and   Violation of Art. I, Sec. I, Para. I of the Georgia Constitution  (by all Plaintiffs against Defendants)   Fraud  (by all Plaintiffs against all Defendants)   Injunctive Relief  (by all Plaintiff Ligocki against Defendants)  108. Plaintiffs incorporate herein and re-allege, as if fully set forth herein,  the allegations of paragraphs 1-17, 22-23, and 28-68.  109. Ligocki is still on probation and is under the supervision of  McDowell-Black and Sentinel.  110. Ligocki seeks an injunction to prevent Defendants from requiring her  and other probationers to submit to drug tests that were not ordered by the Probate  Court.  Ligocki seek an injunction to prevent Sentinel and Sentinel probation  officers from falsely informing probationers that they will be immediately jailed at  the sole discretion of the probation officer if they are unable to pay.    111. Defendants’ conduct is not authorized by any Georgia law and  violates 42 U.S.C. § 1983.    31  112. Defendants’ conduct is likely to continue unless enjoined.  Defendants’ conduct is causing Plaintiff and other current probationers immediate  irreparable harm that cannot be remedied by the award of money damages.   Plaintiff has no plain, adequate, or complete remedy at law to redress the wrongs  described herein.      113. The balance of hardships and public policy strongly favor the Court  entering a preliminary injunction and thereafter permanently enjoining Defendants’  unlawful policies and practices as described herein.    Invasion of Privacy  (by Plaintiff Ligocki against all Defendants)  105. Plaintiffs incorporate herein and re-allege, as if fully set forth herein,  all factual allegations of paragraphs 1-17, 22-23, and 28-68.  106. An individual has a right of privacy regarding her use of a restroom.   McDowell-Black required Ligocki to urinate in a cup with the bathroom door open  in view of a Sentinel employee, without any legal authority.  In so doing, she  intruded on Ligocki’s seclusion in a restroom in a manner that would be offensive  or objectionable to a reasonable person, and that was so to Ligocki.    30  107. Being required to urinate with the bathroom door open in view of a  Sentinel employee caused Ligocki embarrassment and humiliation.  Defendant  McDowell-Black invaded Ligocki’s right to personal privacy in violation of law.    Money Had and Received  (by all Plaintiffs against Defendants)   Tortious Coercion  (by all Plaintiffs against all Defendants)   Unconstitutional Search and Seizure  Violation of the Fourth and Fourteenth Amendments to the United States  Constitution, Brought Under 42 U.S.C. § 1983, and Violation of Art. I, Sec.  I, Para. XIII of the Georgia Constitution  (by all Plaintiffs against Defendants)  