N.D.Iowa: Jail strip search for safety purposes was reasonable

This jail strip search under the jail’s policy for safety purposes was reasonable. United States v. Sutton, 2025 U.S. Dist. LEXIS 10974 (N.D. Iowa Jan. 22, 2025).* Not the countervailing considerations:

Based on my de novo review, I agree with Judge Mahoney and the reasoning this court set forth in Rattray. As the court in Rattray noted, Florence overruled those decisions holding that a strip search always requires reasonable suspicion. Rattray, 908 F. Supp. 2d at 992. Florence concluded that strip searches in which the detainee would be admitted to the general population did not require reasonable suspicion but did not address other circumstances in which a strip search without reasonable suspicion could still be considered reasonable. Those circumstances are still undefined. Nonetheless, Florence provides some guidance as to when a strip search may be reasonable absent reasonable suspicion, citing relevant factors such as safety concerns present at a jail or detention center and the practicalities that correctional officers face during the intake process. See Florence, 566 U.S. at 326. Like other areas of Fourth Amendment jurisprudence, Florence suggests there must be an appropriate balance between protecting one’s privacy and these factors that necessitate the search. Id. at 327 (“The need for a particular search must be balanced against the resulting invasion of personal rights.”); see also Bell v. Wolfish, 441 U.S. 520, 559, 99 S. Ct. 1861, 60 L. Ed. 2d 447 (1979) (instructing that when balancing the need for a particular search against the invasion of personal rights, courts must consider “the scope of the particular intrusion, the manner in which it is conducted, the justification for initiating it, and the place in which it is conducted.”). I find that the strip search performed here pursuant to the jail’s policy strikes the appropriate balance under the circumstances presented.