10. The WCC houses approximately 230 women inmates. Most of the women have been convicted of, or are being detained for, nonviolent offenses. More than a third have mental health problems. Many have been victims of sexual assault or abuse.  11. Inmates at the WCC who cannot remain in general population because they have mental health issues or need to be held in protective custody, or who commit certain disciplinary infractions, are taken to the Segregation Unit.  12. Multiple officers conduct the move. The Shift Commander leads the team, which includes at least three other officers. If the inmate is initially noncompliant, the team includes at least four officers, wearing riot gear.  13. To begin the move, the officers cuff the inmate’s wrists and shackle her ankles. A female officer puts on gloves and conducts a thorough “pat search” of the inmate’s full body.  14. After leading the inmate into a cell in the Segregation Unit, the officers remove the inmate’s cuffs and shackles.  16. An officer tells the inmate to take off all of her clothes. If the inmate is menstruating, she must remove any tampon or pad she is using and hand it to a guard.  17. Once naked, the inmate is ordered to lean forward and run her fingers through her hair, to remove her dentures if she wears them, to raise both arms, and then to lift her breasts. If she has a large midsection, she must “lift her stomach for visual inspection.”  18. A guard tells the inmate to turn around so that she is facing away from the officers. She is ordered to bend over, spread her buttocks apart with her hands, and cough. She must bend over far enough for guards to be able to see inside her anus and vagina.  19. The inmate is ordered to stand up and face the wall, and to remain facing the wall until the officers exit the cell.  20. During this entire process, an officer with a handheld video camera stands just outside the cell, a few feet away.  21. The officer faces the inmate and records her naked body.  22. This officer is almost always a male.  23. The Shift Commander remains inside the cell throughout the strip search. About half the time, the Shift Commander is a male.  25. Massachusetts regulations governing county correctional facilities require that strip- searches be conducted “in relative privacy with as much dignity as possible … by staff the same sex as the inmate.” 103 C.M.R. 924.06(3).  26. American Correctional Association standards state that “[o]nly staff of the same sex as the offender participate in strip searches.” ACA Adult Community Residential Services (4th ed.) 44. This action is brought pursuant to Rule 23(a) and (b) (1) and (3) of the Federal Rules of Civil Procedure by the named Plaintiffs as a class action on behalf of all women taken to the Segregation Unit at WCC whose strip searches were videotaped by a male officer.  45. The named plaintiffs, Debra Baggett and April Marlborough, are members of the class. The class represented by Plaintiffs is so numerous that joinder of all such persons is impractical. The practice described above has existed for a period going back more than three years before this complaint was filed. On information and belief, it has affected several hundred class members.  46. There are questions of law and fact common to the class of plaintiffs. Central to all the claims is the nature and constitutionality of the practice at the WCC of having male guards view and film female inmates being strip searched upon being brought to the Segregation Unit.  47. The named plaintiffs’ claims or defenses are typical of the claims or defenses of the class of plaintiffs.  49. This action is properly maintainable as a class action because the prosecutions of separate actions by the individual members of the class would create a risk of inconsistent or varying adjudications with respect to individual members of the class, which would establish incompatible standards of conduct for the defendants.  50. This action is properly maintainable as a class action because the prosecution of separate actions would create a risk of adjudications with respect to individual members of the class that would, as a practical matter, be dispositive of the interests of the other members who are not parties or would substantially impair or impede their ability to protect their interests.  51. This action is properly maintainable as a class action because the questions of law and fact common to the class predominate over any questions affecting only individual class members, and a class action is superior to other available methods for fairly and efficiently adjudicating the controversy.  52. As a direct result of the policy or practice as described above, class members have been subjected to unlawful strip searches, which have caused each member of the class to endure emotional distress, humiliation, and degradation. VI. 9. The Western Massachusetts Regional Women’s Correctional Center in Chicopee opened in October 2007. It is operated by the Hampden County Sheriff’s Department. It houses women detainees and convicted offenders from the four western counties in Massachusetts. 