Filed Date: Oct. 22, 2015
Closed Date: 2017
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On 10/22/2015, this lawsuit was filed in the U.S. District Court for the District of New Jersey against the Governor of New Jersey and New Jersey Department of Health officials. Plaintiff, a U.S. citizen represented by the ACLU and private counsel, brought claims under 42 U.S.C. §1983, alleging that, upon her return to the United States from a foreign country, Defendants had unlawfully detained and quarantined her in violation of the Fourth and Fourteenth Amendments to the U.S. Constitution. She also alleged false imprisonment and invasion of privacy.
Prior to the incidents giving rise to these allegations, Plaintiff, a nurse specializing in public health, spent approximately one month in Sierra Leone supervising the treatment of patients infected with the Ebola virus. During this time, she followed strict protocol to avoid exposure to the disease. Prior to her return to the U.S., New Jersey Governor Christie signed an Executive Order putting into effect an "Ebola Preparedness Plan" for the state. When she arrived in New Jersey, state and CDC officials escorted Plaintiff to a Quarantine Station, where she was examined and questioned and apparently found to be in good health. Nonetheless, New Jersey Department of Health (DOH) officials and Governor Christie decided to quarantine Plaintiff. Without explaining what was happening and without a signed quarantine order, officials transported Plaintiff in an ambulance to an isolation tent. While there, her temperature was checked several times with two different thermometers, one indicating a normal temperature and the other indicating an elevated temperature. Although Plaintiff tested negative for Ebola and had no symptoms, she was kept in quarantine for a total of 80 hours. During this time, no one gave her an explanation for her detention. In the meantime, Governor Christie addressed the situation on public television, describing Plaintiff as "obviously ill."
On January 15, 2016, Defendants moved to dismiss Plaintiff's complaint. The motion to dismiss argued that Plaintiff's constitutional claims should be dismissed because Defendants were entitled to qualified immunity. It also argued that Plaintiff had failed to state a claim for false imprisonment and invasion of privacy.
On September 2, 2016, District Court Judge Kevin McNulty granted the motion to dismiss with respect to Plaintiff's federal claims. Judge McNulty agreed with Defendants' contention that legal precedent at the time of Plaintiff's quarantine did not clearly establish that detaining Plaintiff and placing her in quarantine violated her constitutional rights. Thus, Defendants were entitled to qualified immunity. He also stated that while there is no bright-line rule for detaining those exposed to infectious disease at the border, authorities possess broad discretion with respect to such matters so long as their orders are not overbroad or unreasonable in relation to the public health interests at stake. 205 F.Supp.3d 579.
However, the court denied Defendants' motion to dismiss with respect to Plaintiff's state law claims, finding that Plaintiff had alleged sufficient facts in support of her claims of false imprisonment and invasion of privacy/false light. 205 F.Supp.3d 579.
The parties requested a stay of discovery, and were soon able to negotiate a settlement. They submitted a stipulated order of dismissal on June 27, 2017. The next day, Judge McNulty ordered the case dismissed with prejudice and without costs to either party. The terms of the settlement agreement included the implementation of less restrictive and more transparent quarantine procedures for those suspected or at-risk of Ebola infection. It also required that quarantined individuals be notified of their rights. There apparently was no financial settlement. The text of the agreement can be found here or with the documents below.
Summary Authors
Lauren Latterell Powell (11/19/2017)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/4517897/parties/hickox-v-christie/
Adams, Erika Rae (New Jersey)
Ahern, Paul Edward (New Jersey)
ANDERSON, MELISSA A. (New Jersey)
ARNOLD, ROSEMARIE (New Jersey)
Assaf, Eugene F. (New Jersey)
Clark, James B. III (New Jersey)
McNulty, Kevin (New Jersey)
Ahern, Paul Edward (New Jersey)
ANDERSON, MELISSA A. (New Jersey)
ARNOLD, ROSEMARIE (New Jersey)
Bahgat, Joseph A. (New Jersey)
Baker, Allyson B. (New Jersey)
Beck, Matthew Evan (New Jersey)
BENNETT, NATALIE FINKELMAN (New Jersey)
Bergman, Andrew D. (New Jersey)
Black, Charles Allen (New Jersey)
Blanchard, Charles Alan (New Jersey)
BRAGDON, TRINA M. (New Jersey)
Braswell, Marina Utgoff (New Jersey)
BRIAN, JEANNETTE M. (New Jersey)
BRICKFIELD, PAUL B. (New Jersey)
Brousseau, Shawn F. (New Jersey)
BURRITT, VALERIE WEISMAN (New Jersey)
Campbell, Rhonda Lisa (New Jersey)
Cardozo, Nathan Daniel (New Jersey)
CARTUSCIELLO, NEIL S. (New Jersey)
Chiesa, Jeffrey S. (New Jersey)
CHIMICLES, NICHOLAS E. (New Jersey)
CONLIN, CYNTHIA ARIEL (New Jersey)
Copeland, Chad Wayne (New Jersey)
DAKESSIAN, LORIE K. (New Jersey)
Davis, Patrick D. (New Jersey)
Dickenson, Scott James (New Jersey)
Dillingham, Emily Newhouse (New Jersey)
Dischley, Lindsay Ann (New Jersey)
Donnelly, Gerard T. (New Jersey)
Dunlap, Thomas Mansfield (New Jersey)
ECKLUND, DONALD A. (New Jersey)
EDWARDS, TIMOTHY D (New Jersey)
Farren, Bridget T. (New Jersey)
Febres-Jorge, Alejandro (New Jersey)
FETTWEIS, ROBERT JOSEPH (New Jersey)
Fields, Rhonda C. (New Jersey)
Francis, Tricia Dianne (New Jersey)
GEHRING, MICHAEL E. (New Jersey)
George, J. Timothy (New Jersey)
Gillers, Gillian B. (New Jersey)
Gilmore, Scott A. (New Jersey)
Gleason, Edward M. (New Jersey)
Glick, Michael A. (New Jersey)
Goldfluss, Lisa Sheri (New Jersey)
Graunke, Kristi L. (New Jersey)
Greenstein, Alan Judah (New Jersey)
Hagebols, Mary Shea (New Jersey)
HAGLER, ANDREW S. (New Jersey)
HAMILL, PATRICIA M. (New Jersey)
Hannon, J. Michael (New Jersey)
Harting, John Kelly (New Jersey)
Hausfeld, Michael David (New Jersey)
HEVENOR, E. WILLIAM (New Jersey)
HOBAN, PATRICIA M. (New Jersey)
Holmes, W. Clifton (New Jersey)
HORWITZ, MELISSA ANN (New Jersey)
HUGHES, WILLIAM CHARLES (New Jersey)
Huq, Aziz Zahirul (New Jersey)
Interrante, John G. (New Jersey)
Israel, Ronald Lawrence (New Jersey)
Jespersen, Kevin R. (New Jersey)
Johnson, Bradford Paul (New Jersey)
JOHNSON, RICHARD ERROL (New Jersey)
JR., CHARLES THOMAS (New Jersey)
Kaiser, Matthew G. (New Jersey)
Kassier, Andrew M. (New Jersey)
Kaufman, Jonathan Gaynor (New Jersey)
KENNEY, JOSEPH B. (New Jersey)
KENT, KEVIN DOOLEY (New Jersey)
King, Laurence D. (New Jersey)
Levesque, Christian Alexandra (New Jersey)
Maack, Marcia Tavares (New Jersey)
Marconda, Scott Michael (New Jersey)
Martinez, Richard M. (New Jersey)
Mayo, Courtney E. (New Jersey)
MCANDREWS, DENNIS C. (New Jersey)
McBarnette, Andrea (New Jersey)
MCGETTIGAN, JOSEPH E. (New Jersey)
McMahon, Martin F. (New Jersey)
McOwen, Maureen E. (New Jersey)
Miller, Andrew Michael (New Jersey)
Muha, Christopher C. (New Jersey)
Nelson, Christopher L. (New Jersey)
O'Quinn, John Caviness (New Jersey)
Perry, Amanda Fox (New Jersey)
Peterson, Marka Ann (New Jersey)
Pietranton, Erica M. (New Jersey)
Ramos-Mrosovsky, Carlos (New Jersey)
Rehfuss, Stephen J. (New Jersey)
Reilly, John Joseph (New Jersey)
RICHMOND, KENNETH WILLIAM (New Jersey)
RYWANT, MICHAEL S (New Jersey)
Scheff, Richard L. (New Jersey)
Scherer, William R. (New Jersey)
SCHROM, GERARD K. (New Jersey)
Seplow, Michael D (New Jersey)
Smith, Johnathan James (New Jersey)
Smith, Gregory S. (New Jersey)
Sprayregen, James H. (New Jersey)
Stoltz, Mitchell L. (New Jersey)
STRATIS, DEMETRIOS K. (New Jersey)
Subar, Judry Laeb (New Jersey)
Subbaraman, Mahesha P. (New Jersey)
Sullivan, Diane M. (New Jersey)
TAYLOR, LINDSEY H. (New Jersey)
Teresi, Gregory J. (New Jersey)
Thomashower, William (New Jersey)
Tracey, Maureen P (New Jersey)
Umana, Idotenyin Hope (New Jersey)
Vahlsing, Marissa (New Jersey)
VARTAN, LEE DAVID (New Jersey)
Walling, Samuel L. (New Jersey)
Whitaker, Claire M. (New Jersey)
WHITE, CHRISTIAN R. (New Jersey)
See docket on RECAP: https://www.courtlistener.com/docket/4517897/hickox-v-christie/
Last updated March 20, 2024, 3:06 a.m.
State / Territory: New Jersey
Case Type(s):
Special Collection(s):
Key Dates
Filing Date: Oct. 22, 2015
Closing Date: 2017
Case Ongoing: No
Plaintiffs
Plaintiff Description:
Private citizen held and quarantined at the U.S. border.
Plaintiff Type(s):
Attorney Organizations:
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
New Jersey Department of Health, State
Defendant Type(s):
Case Details
Causes of Action:
Constitutional Clause(s):
Unreasonable search and seizure
Available Documents:
Injunctive (or Injunctive-like) Relief
Outcome
Prevailing Party: Plaintiff
Nature of Relief:
Injunction / Injunctive-like Settlement
Source of Relief:
Form of Settlement:
Content of Injunction:
Issues
General:
Jails, Prisons, Detention Centers, and Other Institutions: