Upon her return through the Cordova port of entry at approximately 2 p.m., Doe was randomly selected for additional screening at a secondary inspection area, the complaint states. Doe was allegedly frisked through her clothing, over her genital area, and in the crevice of her buttocks with a finger by a CBP agent. No drugs or contraband were found.

Doe was then directed to return to a line with other people, when a CBP dog allegedly lunged onto her, “landing its front paws on her torso.”

The complaint says that Doe then was led to a private room and strip searched by CBP agents.

Doe was ordered to pull down her pants and crouch, as a CBP agent “examined her anus with a flashlight;” then she was “commanded to lean backwards in her crouched position,” while one of agents “parted Ms. Doe’s vulva with her hand, pressed her fingers into Ms. Doe’s vagina and visually examined her genitalia with a flashlight.”

“The strip search did not produce any evidence of contraband or of internal drug smuggling,” states the complaint.

Doe’s attorneys state that she was humiliated and began crying as agents taped the cuffs of her pants to her legs and placed her in handcuffs. At about 4 p.m., she was transported to the University Medical Center of El Paso.

“During the car ride to the Medical Center, Ms. Doe asked if the agents had a warrant. One of them responded that they did not need a warrant,” the complaint states.