Law School Case Brief
Hudson v. Palmer - 468 U.S. 517, 104 S. Ct. 3194 (1984)
The proscription against unreasonable searches under U.S. Const. amend IV does not apply within the confines of the prison cell.
Petitioner Hudson, a correctional officer at Bland Correctional Center, conducted a search of respondent Palmer’s prison cell for contraband. During the search, a ripped pillowcase was found in a trashcan near respondent's cell. Charges were filed against respondent, and he was ordered to reimburse the state for the destroyed material. Respondent then filed an action in district court under 42 U.S.C.S. § 1983, alleging that certain of his personal property was destroyed in violation of his right to due process of law. The district court granted petitioner's motion for summary judgment. The court of appeals reversed and remanded on the basis that respondent had a limited privacy right in his cell, entitling him to protection against searches conducted solely to harass or to humiliate. Petitioner sought review.
Within the confines of a prison cell, does an inmate have a "justifiable" or reasonable expectation of privacy in his prison cell such that the Fourth Amendment proscription against unreasonable searches applies?
On certiorari, the Supreme Court of the United States held that respondent Palmer had no legitimate expectation of privacy and that the prohibition on unreasonable searches under U.S. Const. amend IV did not apply to prison cells. The recognition of privacy rights for prisoners in their individual cells simply cannot be reconciled with the concept of incarceration and the needs and objectives of penal institutions. The Court further held that intentional deprivation of property by the state could not violate due process under U.S. Const. amend. XIV if a post-deprivation remedy was available. The Court concluded that several state law remedies were available to respondent to provide adequate compensation for his loss.
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