Florence v. Board of Chosen Freeholders of the County of Burlington

The elimination of contraband in correctional facilities requires reasonable search procedures, and courts should defer to prison officials as to the reasonableness of these procedures.

After Petitioner was pulled over for speeding and arrested on a bench warrant issued two years prior for failure to pay a monthly installment on a fine, he was forced to go through a standard delousing process and strip search at two detention locations. Petitioner filed a suit under 42 U.S.C § 1983 for a violation of his Fourth and Fourteenth Amendment rights, arguing that officials could not conduct strip searches without particularized reasonable suspicion. The district court granted Petitioner’s summary judgment motion and the Court of Appeals for the Third Circuit reversed.

The Supreme Court affirmed the Third Circuit's decision. The Supreme Court stated that corrections officials must be given "substantial discretion" to maintain safety at a correctional facility and that the impingement on the detainee’s right must be upheld if it is "reasonably related to legitimate penological interests." The Court held that the definition of reasonableness will be left to the officials unless there is substantial evidence of an "exaggerated response" to a legitimate security interest. The Court also held that Petitioner's proposal that new detainees not arrested for serious or dangerous crimes be exempt from invasive searches, is unworkable and is not required by the Fourth or Fourteenth Amendment.