Florence v. Board of Chosen Freeholders of County of Burlington, 132 S. Ct. 1510

Florence arrested on warrant and detained in New Jersey facilities during intake.
Burlington County and Essex County jails required detainees to undress for visual inspection to detect contraband, injuries, and gang affiliations.
Policy applied uniformly to all detainees entering general population, regardless of arrest circumstances or behavior.
Florence sued under 42 U.S.C. §1983 alleging Fourth and Fourteenth Amendment violations for unlawful strip searches.
District Court granted summary judgment for Florence; Third Circuit reversed; case before the Supreme Court for review.
Court defers to correctional officials’ expertise absent substantial evidence of exaggerated response; upholds the challenged searches as reasonable under existing framework.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether suspicionless strip searches of arrestees entering general population are constitutional.	Florence argues searches violate Fourth Amendment without reasonable suspicion.	Corrections may perform thorough intake searches to deter contraband.	No; such policy deemed reasonably related to security interests.
Whether exemptions for minor offenses are feasible or warranted.	Exemption for minor offenses would be workable and safer.	Exemption would be unworkable and riskier for facility security.	Exemption not adopted; system-wide policy maintained.
How deference to correctional officials interacts with Atwater/Bell framework.	Court should scrutinize administrative discretion closely.	Court should defer to professional expertise under penological interests.	Deference maintained; policy reasonable under Turner/Bell framework.

Bell v. Wolfish, 441 U.S. 520 (1979) (balancing test for prison searches; deference to security needs)
Turner v. Safley, 482 U.S. 78 (1987) (deference to prison administrators; reasonably related to legitimate penological interests)
Block v. Rutherford, 468 U.S. 576 (1984) (courts defer to corrections officials absent substantial evidence of exaggeration)
Atwater v. Lago Vista, 532 U.S. 318 (2001) (arrest power for minor offenses; administrability of rules)
Hudson v. Palmer, 468 U.S. 517 (1984) (recognizes broad warrantless searches to deter contraband in prisons)
Mary Beth G. v. Chicago, 723 F.2d 1263 (7th Cir. 1984) (privacy harms of visual body-cavity searches; demeaning and intrusive)
Shain v. Ellison, 273 F.3d 56 (2d Cir. 2001) (empirical data on body-cavity searches; contraband findings)
Bull v. City and County of San Francisco, 595 F.3d 964 (9th Cir. 2010) (en banc; reasonable-suspicion standard for minor-offense arrestees)