The Supreme Court recently delivered its opinion in Florence v. Board of Freeholders. The Supreme Court upheld the validity of strip searches of jail detainees who are being detained for minor offenses. The key inquiry in the case surrounded the type of suspicion required before officials can initiate a strip search of a detainee. It was Florence's proposition that officials need a reasonable, individualized suspicion that the detainee is armed or carrying contraband before an official can conduct the strip search. However, the Court rejected the argument, determining officials are justified in strip searching all detainees. Justice Kennedy wrote in the opinion that such procedures are a reasonable balance between the detainee's privacy and the safety precautions needed for a detention facility.

The ruling in Florence v. Board of Freeholders was delivered eight years after Florence was arrested. Florence was arrested in 2005 during a traffic stop for an outstanding warrant that was vacated by the issuing judge but never removed from the state records. Florence was detained in the county jail and then later transferred to another correctional facility. Florence was subjected to a strip search at both facilities.