What is the current state of the law on strip searches in prisons?

One need not subscribe in full measure to the foregoing statements to realize that a problem of employee honesty and ethics exists in every correctional institution. See, e.g., United States v. McCrary, 699 F.2d 1308, 1311-12 (11th Cir.1983). It is essential, therefore, that prison administrators be accorded "wide-ranging deference in the adoption and execution of policies and practices that in their judgment are needed to preserve internal order and discipline and to maintain institutional security." Bell v. Wolfish, supra, 441 U.S. at 547, 99 S.Ct. at 1878.

At first blush, a holding that no strip search may take place in the absence of a reasonable suspicion that contraband will be found does not seem to place too heavy a burden on prison administrators. However, I believe we reasonably may expect that, after the majority opinion is filed, appellants and their colleagues will challenge every search that is made, see Gettleman v. Werner, 377 F.Supp. 445, 449 (W.D.Pa.1974); and I can think of no better way to dry up sources of information than to require prison officials to disclose in each instance the basis for their reasonable suspicion. Moreover, the majority's "Application of the Reasonable Suspicion Standard", with the results of which I in some instances disagree, presages additional judicial involvement in prison administration, and makes civil contempt or section 1983 liability contingent on the ex post facto determination by a judge or jury of what constitutes reasonable suspicion.

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