CA2: Merely having knowledge of prison strip searches doesn’t make that prison official potentially liable

Merely having knowledge of prison strip searches doesn’t make that prison official potentially liable. Baltas v. Jones, 2025 U.S. App. LEXIS 32676 (2d Cir. Dec. 15, 2025)*:

There are two Fourth Amendment tests for prisoner strip searches. “[I]f the inmate’s Fourth Amendment claim challenges an isolated search, courts typically apply the standard set forth in Bell v. Wolfish, 441 U.S. 520 (1979).” Id. at 58. If, instead, the challenge is to a “policy” of conducting strip searches, “courts typically analyze the claim under Turner v. Safley” and uphold it “if it is reasonably related to legitimate penological interests.” Id. at 57-58 (quoting Turner, 482 U.S. at 89). Because Baltas does not identify any particular strip search with specificity, and instead objects to the blanket policy of strip-searching him whenever he left his cell, Turner is the relevant framework.

. . .

Baltas points to only two indications of Jones’s personal involvement in the strip-search policy: that she saw some of the strip searches, and that Baltas complained to her that he was being strip-searched. Baltas’s particular allegations of awareness and failure to act are insufficient to show that Jones was personally involved in the strip-search policy that he asserts violates his rights under the Fourth Amendment. Rather, it is analogous to the holding Turkmen disavowed: that mere knowledge of strip searches suffices for personal involvement in a Fourth Amendment violation. See id. at 261. Summary judgment was therefore properly granted on the Fourth Amendment claim.