11.  In or around October 2012 through November 2012, Plaintiff Amanda Sumpter was  housed as an inmate at the Wayne County Jail.   12.  During her incarceration at the Wayne County Jail, Plaintiff Sumpter was subjected to  unreasonable, unlawful, and unconstitutional strip searches conducted by agents and/or  employees of the Wayne County Sheriff.   13.  Specifically, the Wayne County Sheriff has allowed an unconstitutional policy, custom  and practice to flourish within the Wayne County Jail whereby female inmates are  forcibly exposed in a state of undress to male guards, officers, employees, and other male  5:14-cv-14769-JCO-RSW   Doc # 1   Filed 12/17/14   Pg 2 of 8    Pg ID 2 3  inmates.   14.  During strip searches, Plaintiff, and hundreds of other female inmates were made to strip  down naked in common areas of the Wayne County Jail and in view of male officers as  well as other inmates.   15.  During such strip searches, Plaintiff, and hundreds of other female inmates, were forced  to bend over and spread their vaginal parts and anus under the pretense of searching for  contraband.   16.  Defendants conducted these unreasonable and unconstitutional strip searches even if the  female inmates were experiencing menstrual cycles which would often result in  menstrual discharges in the common areas of the jail during these en masse strip  searches.   17.  During these unconstitutional strip searches, Plaintiff and hundreds of other female  inmates would see and hear the male officers laughing and otherwise mocking them  while standing naked and being forced to expose themselves.   18.  These strip searches, which were often conducted in groups, were conducted without  reasonable suspicion that any particular inmates were in the possession of contraband.   19.  Often times these unreasonable and unconstitutional strip searches occurred before and  after the female inmates were taken to court proceedings and/or medical examinations  during which the female inmates were always in the presence of correctional officers.   20.  Plaintiff was subjected to several unreasonable and unconstitutional strip searches  between October and November 2012.     21.  Upon information and belief, Defendant Graham routinely conducted the types of strip  5:14-cv-14769-JCO-RSW   Doc # 1   Filed 12/17/14   Pg 3 of 8    Pg ID 3 4  searches described herein.   22.  Plaintiff was also forcibly exposed to male deputies who often worked in the stations  adjacent to the female inmates’ housing unit.   23.  The male deputies who were assigned to the female housing unit had direct view into the  cells of several female inmates including views of the inmate toilets.   24.  The male deputies who were assigned to the female housing unit had direct view into the  shower areas of the female inmates.      25.  Furthermore, on the midnight shift when the female inmates were asleep, male officers  would often perform rounds and check on the inmates in their cells when the female  inmates were often in a state of undress.   26.  During such rounding of the cells throughout the night, the male officers did not  announce their presence.   27.  Plaintiff and other female inmates were often degraded, humiliated, and subjected to  inhumane and cruel treatment as described herein for no legitimate penological interest  but rather to embarrass, humiliate, and degrade them.   28.  Plaintiff suffered extreme emotional distress, humiliation, embarrassment, and damage as  a result of Defendants’ degrading, humiliating, and cruel actions.  29.  Plaintiff hereby incorporates by reference herein the allegations contained in the above  Paragraphs of the complaint.   30.  The acts of Defendants as ratified, endorsed, and cultivated by Wayne County and its  Sheriff as described herein violated Plaintiff’s privacy rights as guaranteed by the Fourth  5:14-cv-14769-JCO-RSW   Doc # 1   Filed 12/17/14   Pg 4 of 8    Pg ID 4 5  Amendment to the United States Constitution.   31.  Defendants’ actions as described herein were undertaken without regard to any legitimate  penological interest.   32.  Defendants’ acts of forcibly exposing Plaintiff to be seen naked by male deputies and  male inmates constituted an unreasonable invasion of privacy in violation of the Fourth  Amendment.   33.  Defendants’ actions were not taken spontaneously in response to an emergency, but  rather in conformity with the County and Sheriff’s Department’s deliberate policies,  customs, and practices.   34.  The constitutional rights that Defendants violated were clearly established at all times  when Defendants violated such rights and a reasonable person in Defendants’ position  would have understood that their conduct was in violation of those rights.   35.  Defendants are therefore not entitled to qualified immunity.   36.  By virtue of Defendants’ actions, Plaintiff is entitled to compensatory and punitive  damages.  37.  Plaintiff hereby incorporates by reference herein the allegations contained in the above  Paragraphs of the complaint.   38.  Defendants County of Wayne and Wayne County Sheriff employed the use of  unconstitutional policies, practices, and customs relating to strip searches that resulted in  the violation of Plaintiff’s constitutional rights under the Fourth Amendment.  5:14-cv-14769-JCO-RSW   Doc # 1   Filed 12/17/14   Pg 5 of 8    Pg ID 5 6   39.  Specifically, Defendants County and its Sheriff allowed the following unconstitutional  policies, practices, and customs to flourish in the Wayne County Jail:  a. subjecting female inmates to strip searches in en masse without regard to the  inmates’ privacy rights.  b. subjecting female inmates to strip searches in the presence of or within view  of members of the opposite sex; and   c. forcibly exposing female inmates to spread and expose their vaginal areas  without regard to the inmates’ privacy rights and in the presence of members  of the opposite sex and other inmates.     40.  Defendants’ unconstitutional polices, practices, and customs as described herein served  no legitimate penological interest.  41.  Plaintiff hereby incorporates by reference herein the allegations contained in the above  Paragraphs of the complaint.   42.  Defendants County of Wayne and its Sheriff had an obligation to train its employees  and/or agents regarding the constitutional rights of citizens under the Fourth Amendment  including the right to privacy.   43.  Defendants County of Wayne and its Sheriff had an obligation to supervise its agents and  employees, including the individual Defendants named herein, to insure that the  constitutional rights of Plaintiff and similarly situated female inmates were not violated.   44.  Defendants County of Wayne and its Sheriff failed to comply with its duty to train and/or  5:14-cv-14769-JCO-RSW   Doc # 1   Filed 12/17/14   Pg 6 of 8    Pg ID 6 7  supervise its employees and/or agents and had a custom or policy of acting with  deliberate indifference to violations of the constitutional rights of Plaintiff and other  similarly situated female inmates.   45.  By inadequately training and/or supervising its employees and agents and having a  custom or policy of deliberate indifference to the constitutional rights of Plaintiff,  Defendants encouraged and cultivated the conduct that resulted in the violation of  Plaintiff’s constitutional rights.   46.  Defendants’ policies, practices, and customs were the moving force in causing Plaintiff  her injuries as described herein.   47.  By virtue of the actions of Defendant County of Wayne and its Sheriff, Plaintiff is  entitled to compensatory and punitive damages.  COUNTY SHERIFF FOR ITS UNCONSTITUTIONAL POLICES, CUSTOMS, AND  PRACTICES   COUNTY SHERIFF FOR INADEQUATE TRAINING AND/OR SUPERVISION OF  ITS AGENTS AND EMPLOYEES REGARDING THE CONSTITUTIONAL RIGHTS  OF CITIZENS  