Hudson v. Palmer

Case Date: 12/07/1983
Docket No: none

Facts of the Case 

Russell Palmer, a prisoner in a Virginia prison, brought suit against Ted Hudson, an officer at the institution. Hudson had conducted a "shakedown" search of Palmer's locker and cell for contraband. Hudson and another officer also charged Palmer with destroying state property after they discovered a ripped pillowcase near Palmer's cell bunk. Palmer was then ordered to reimburse the State.

Question 

Did the search of Palmer's locker and cell violate the Fourth Amendment? Did prison officials deprive Hudson of his property in violation of the Fourteenth Amendment?

Argument Hudson v. Palmer - Oral ArgumentFull Transcript Text  Download MP3 Conclusion  Decision: 5 votes for Hudson, 4 vote(s) against Legal provision: Amendment 4: Fourth Amendment

The Court held that the Fourth Amendment proscription against unreasonable searches did not apply "within the confines of the prison cell." Noting that privacy was fundamentally incompatible with the maintenance of prison security and surveillance, the Court found that "the paramount interest in institutional security" outweighed all privacy concerns. The Court further held that "random and unauthorized" deprivations of property did not violate the Due Process Clause, so long as postdeprivation remedies were available.