Anthony Haywood and Daniel Hall appealed a circuit court judgment that dismissed claims against Sheriff Dorothy "Jean Dot" Alexander, which were filed as part of a counterclaim in an action filed against Phillip Eugene Green, Haywood, and Hall by Scott Cotney, an administrator at the Clay County jail. In 2010, Cotney sued Green, a former correctional officer at the jail, and Haywood and Hall, former inmates at the jail, alleging defamation, slander, libel, invasion of privacy, negligence, and wantonness. The claims resulted from a report filed by Green, Haywood, and Hall with the Alabama Department of Corrections, claiming that Cotney had used his position as an administrator at the jail to sexually abuse and/or to assault Haywood and Hall while they were incarcerated in the jail. Haywood and Hall argued that the circuit court erred in granting Sheriff Alexander's motion to dismiss the claims against her. Specifically, they argued: (1) that their failure to identify Sheriff Alexander as a third-party defendant rather than a counterclaim defendant was not fatal to their complaint; (2) that Haywood and Hall were convicted felons, not pretrial detainees, during the relevant period and therefore had certain rights under the Eighth Amendment; (3) that Haywood's and Hall's rights pursuant to Fourth Amendment were violated because they were subject to "numerous acts of unlawful strip searches and bodily invasion perpetrated upon them by Cotney while he was the administrator of the [jail]"; (4) that Sheriff Alexander was not entitled to immunity under the State or Federal constitutions. Upon review, the Supreme Court affirmed the judgment in part, reversed it in part, and remanded the case for further proceedings. Haywood and Hall did not demonstrate any error in the circuit court's decision to dismiss the federal claims against Sheriff Alexander in her official capacity or the state-law claims against her in both her official and individual capacities. Therefore, the circuit court's judgment was affirmed insofar as it dismissed those claims. However, at this stage of the proceedings Sheriff Alexander was not entitled to a dismissal of the federal claims against her in her individual capacity.
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