Cantley v. The West Virginia Regional Jail and Correctional Facility Authority, 3:09-cv-00758

Cantley and Teter, on behalf of themselves and others, allege prearrest strip searches and delousing at WV Regional Jail facilities violated the Fourth and Fourteenth Amendments and §1983.
Cantley was arrested on non-felony DVPO charges and strip searched/deloused after arraignment at Western Regional Jail; he remained in general population for over a month.
Teter was arrested on misdemeanors, strip searched and deloused at Tygart Valley facility; searches occurred before arraignment under blanket policy.
Florence v. Board of Chosen Freeholders (2012) governs whether prearraignment blanket searches are reasonable, balancing security against privacy.
Court grants summary judgment for defendants, denying Cantley and Teter’s claims; class certification pending, but the case proceeds only on Cantley and Teter’s individual claims.
The court analyzes Florence, Bell v. Wolfish, and Turner framework to assess reasonableness and deference to correctional officials.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Cantley’s post-arraignment visual cavity search violated rights under Florence.	Cantley—search violated Fourth Amendment.	Search within Florence’s reasonable balance framework.	No violation; search upheld under Florence.
Whether Teter’s blanket pre-arraignment strip searches violated rights under Florence/ Bell.	Teter— blanket searches unconstitutional.	Deterrence of contraband justified; blanket searches reasonable.	No constitutional violation; balance favored officials.
Whether the delousing policy violates detainees’ privacy or constitutes unlawful medical treatment.	Delousing is intrusive; ineffective and unnecessary.	Policy reasonable to prevent lice; deference to prison officials.	Policy deemed reasonably related to penological interests; no violation.
Whether Defendants are entitled to summary judgment on qualified immunity/extra grounds.	Claims present constitutional violations.	No clearly established violation; deference to officials.	Court grants summary judgment for defendants on these claims.
Whether a class should be certified given the procedural posture.	Class action status controls relief.	No class certification; individual claims decided.	No class certification; case dismissed as to plaintiffs' claims.

Florence v. Bd. of Chosen Freeholders, 132 S. Ct. 1510 (U.S. 2012) (upheld reasonable protective searches balancing security and privacy in jail intake)
Bell v. Wolfish, 441 U.S. 520 (U.S. 1979) (weighing confinement security against privacy interests in pretrial detention)
Turner v. Safley, 482 U.S. 78 (U.S. 1987) (reasonable relation between prison regulation and legitimate penological interests)
Logan v. Shealy, 660 F.2d 1007 (4th Cir. 1981) (early handling of detainee strip searches; distinguishable from current facts)
Amaechi v. West, 237 F.3d 356 (4th Cir. 2001) (cases about force and privacy in searches; distinction from spraying delousing)