## Facts

- Kristin A. Greenawalt worked as a research analyst for the Indiana Department of Corrections (IDOC).
- About two years into her employment, she was told she had to submit to a psychological examination to keep her job; the complaint did not state why the demand was made at that time.
- Greenawalt took a two-hour psychological test that asked about details of her personal life.
- She sued under 42 U.S.C. § 1983, alleging the compelled test was an unreasonable search under the Fourth Amendment.
- She also asserted Indiana tort claims for invasion of privacy and intentional or deliberate infliction of emotional distress, and sought damages plus an injunction ordering expungement of the test results from her personnel file.

## Issues

1. Whether a compelled, highly personal psychological test required as a condition of continued public employment constitutes a “search” under the Fourth Amendment.
2. If it is a search, whether the complaint plausibly alleged that the search was unreasonable under the Fourth Amendment for purposes of § 1983.
3. Whether qualified immunity bars claims against individual officials, including requests for injunctive relief.

## Decision

- The Seventh Circuit affirmed dismissal of the federal § 1983 claim.
- The court held the psychological test did not constitute a Fourth Amendment “search,” so there was no Fourth Amendment violation.
- The court noted the district court erred in treating qualified immunity as barring injunctive relief, because qualified (official) immunity applies only to damages.
- Because the federal claim failed on the merits, the case did not turn on qualified immunity, and the relinquishment of supplemental jurisdiction over the state-law claims remained in place.

## Legal Principles

- The Fourth Amendment’s “search” concept is directed primarily at physical or analogous intrusions; mandatory questioning, even if personal, is not itself a “search.”
- The Fourth Amendment is not a general privacy protection for all intrusive government conduct; intrusive employment-related questioning may implicate other legal protections without triggering Fourth Amendment search doctrine.
- Qualified (official) immunity is a defense to damages liability and does not, by itself, bar prospective injunctive relief against officials.

## Conclusion

The court held that compelling a state employee to complete a two-hour psychological test as a condition of employment did not amount to a Fourth Amendment search; without a search, there was no constitutional violation actionable under § 1983, leaving any relief for alleged intrusiveness to state-law remedies rather than Fourth Amendment litigation.


Greenawalt v. Ind. Dep’t of Corr., 397 F.3d 587 (7th Cir. 2005)