Part II of this Note will provide an historical judicial background of the decisions leading up to the Powell v. Barrett decision. This section will first take a brief look at the history of the prison strip search before conducting an in-depth analysis at the Bell v. Wolfish decision, including the facts, rationale, and ambiguities of the decision. Next, this Note will examine the subsequent use of the Bell v. Wolfish decision by the federal courts in the context of strip searches conducted pursuant to facilities' booking policies, focusing on the rise of the “reasonable suspicion” standard. Part III of this Note will look at the decision in Powell itself. This section will start by examining the factual background of the case. It will then delve into a detailed analysis of the rationale that the Eleventh Circuit employed to reach its decision and demonstrate why this rationale is misapplied in light of the Supreme Court's decision in Bell v. Wolfish and the federal court decisions that followed. Finally, this Note will examine reactions from other circuit courts since the Eleventh Circuit decided Powell.
Note, Stripped of Justification: The Eleventh Circuit's Abolition of the Reasonable Suspicion Requirement for Booking Strip Searches in Prisons, 57 Clev. St. L. Rev. 893 (2009)