## Facts

- Kaci Hickox, a nurse who treated Ebola patients in Sierra Leone during the 2014–2016 epidemic, returned to the United States through Newark Liberty International Airport in October 2014.
- New Jersey had implemented an Ebola preparedness policy shortly before her arrival.
- At the airport, Hickox was examined and questioned by officials and appeared to be in good health, but she was nonetheless quarantined.
- Without a signed written quarantine order or clear explanation, officials transported her by ambulance to an isolation tent.
- Her temperature was taken multiple times with conflicting readings; she tested negative for Ebola and had no symptoms.
- Hickox was held for roughly 80 hours and alleged poor communication and lack of clarity about the quarantine process and what would happen next.
- Governor Chris Christie made public statements about Hickox, including describing her as “obviously ill,” despite her negative test and lack of symptoms.
- Hickox sued state officials under 42 U.S.C. § 1983 for alleged Fourth and Fourteenth Amendment violations and asserted New Jersey tort claims for false imprisonment and false light.

## Issues

1. Whether the approximately 80-hour quarantine constituted an unreasonable seizure under the Fourth Amendment, and whether qualified immunity barred damages.
2. Whether the quarantine violated substantive due process liberty interests under the Fourteenth Amendment, and whether qualified immunity barred damages.
3. Whether the lack of prompt notice, written order, or hearing violated procedural due process under the Fourteenth Amendment, and whether qualified immunity barred damages.
4. Whether the New Jersey tort claims for false imprisonment and false light were plausibly pleaded and could proceed at the motion-to-dismiss stage.

## Decision

- The court granted the motion to dismiss the federal § 1983 claims on qualified immunity grounds.
- The court held the officials had at least probable cause (or its public-health equivalent) to impose quarantine given Hickox’s recent exposure risk, the seriousness of Ebola, uncertainty at the time, and conflicting temperature readings.
- The court ruled it was not clearly established that a short-term, medically supervised quarantine under these circumstances violated substantive due process.
- The court ruled it was not clearly established that immediate notice or a hearing was constitutionally required for a short-term emergency quarantine for a highly dangerous disease.
- The court denied dismissal of the New Jersey false imprisonment and false light claims, finding the allegations plausible at the pleading stage.

## Legal Principles

- Qualified immunity bars § 1983 damages unless the plaintiff pleads a violation of clearly established constitutional law such that unlawfulness would be apparent to a reasonable official in the circumstances.
- In emergency public health contexts, courts may afford officials latitude where existing precedent does not clearly define constitutional limits on quarantine measures.
- A Fourth Amendment seizure claim tied to quarantine may fail at the qualified-immunity stage if officials had a reasonable basis to believe detention was lawful based on exposure risk and disease severity.
- Substantive and procedural due process claims arising from emergency quarantine are subject to qualified immunity when precedent does not clearly require different safeguards for short-term confinement.
- Under New Jersey law, false imprisonment may be plausibly alleged by intentional, unauthorized restraint; asserted justifications commonly require factual development beyond pleadings.
- Under New Jersey law, false light may be plausibly alleged where widely disseminated statements could be false and highly offensive.

## Conclusion

The court dismissed Hickox’s federal constitutional damages claims because the asserted limits on short-term Ebola quarantine were not clearly established in 2014, entitling officials to qualified immunity, but it allowed her New Jersey tort claims for false imprisonment and false light to proceed past the pleading stage.


Hickox v. Christie, 205 F. Supp. 3d 579 (D.N.J. 2016)