If there is an animating imperative behind the Supreme Court’s decision in Bell v. Wolfish, it is this: when confronted with a question regarding stripsearching arrestees, courts must seek a careful balance. Decades later, the Court appears to have deviated from Bell’s moorings. Last Term, in Florence v. Board of Chosen Freeholders, the Court examined the constitutionality of blanket search policies that require that all arrestees be strip-searched regardless of individualized suspicion or the nature of the offense. I argue in the following analysis that Florence constitutes an unnecessary erosion of Fourth Amendment protections for arrestees.


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