Second Circuit
Poe v. Leonard, 282 F.3d 123, 126 (2d Cir. 2002) (“By 1993, it was clearly established that a police officer violates a person’s Fourteenth Amendment right to bodily privacy when that officer views, photographs or otherwise records another’s unclothed or partially unclothed body, without that person’s consent. By 1993, it was also clearly established that a supervisor could be liable if he had actual or constructive notice that it was highly likely his subordinate, while on duty, might violate another’s right to privacy in his or her unclothed body, but the supervisor deliberately or recklessly disregarded that risk by failing to take reasonable action to prevent such a violation, and that failure caused the constitutional injury to the plaintiff.”).