Videotape of search for inmate's contraband phone did not conclusively establish how search was conducted and where phone was located, and thus did not provide sufficient basis for granting officers’ motion for summary judgment in action alleging that officers violated Fourth and Eighth Amendments by violently pulling contraband phone out of his rectum in prison shower.
In deciding whether in-prison search violates Fourth Amendment, court considers: (1) scope of particular intrusion; (2) manner in which it is conducted; (3) justification for initiating it; and (4) place in which it is conducted; genuine issue of material fact as to whether correctional officers’ purported use of force against inmate—including slamming him to ground, forcing him on to his stomach, and handcuffing him, and then grabbing his hair and yanking his head back and forth, and violently pulling contraband phone out of his rectum in prison shower—was reasonable and justified by reaso