## Facts

- Federal officials operated the Metropolitan Correctional Center (MCC), a short-term federal detention facility in New York City primarily housing pretrial detainees.
- Overcrowding led the MCC to house two detainees in rooms designed for single occupancy (double-bunking).
- Detainees filed a certified class action challenging multiple confinement conditions and practices as unconstitutional punishment and as violations of the First, Fourth, and Fifth Amendments.
- Challenged practices included double-bunking, a “publisher-only” rule for hardcover books, restrictions on outside packages of food and personal items, visual body cavity searches after contact visits, and room inspections requiring detainees to leave their rooms.
- The district court and the Second Circuit enjoined several practices, applying a “compelling necessity” standard for restrictions on pretrial detainees.

## Issues

1. Under the Fifth Amendment Due Process Clause, when do conditions or restrictions on pretrial detainees constitute unconstitutional punishment?
2. Whether double-bunking pretrial detainees at the MCC violated due process.
3. Whether the “publisher-only” rule for hardcover books and restrictions on packages violated the First Amendment or due process.
4. Whether suspicionless visual body cavity searches after contact visits violated the Fourth Amendment.
5. What level of deference courts must give correctional administrators in adopting security and order policies.

## Decision

- The Supreme Court reversed in large part and upheld the challenged MCC practices.
- The Court rejected the “compelling necessity” test and held that the proper inquiry is whether a condition amounts to punishment.
- Double-bunking was upheld as reasonably related to legitimate administrative and security objectives in a short-term facility.
- The publisher-only rule and package restrictions were upheld as reasonable, security-related regulations.
- Visual body cavity searches after contact visits were upheld as reasonable under the Fourth Amendment despite the absence of individualized suspicion.
- Unannounced room searches and temporary lockouts during inspections were upheld as permissible security measures.
- The Court emphasized wide-ranging deference to jail administrators on matters of internal security and order.

## Legal Principles

- Pretrial detainees may not be punished before adjudication of guilt, but not every hardship or loss of privacy inherent in detention constitutes punishment.
- A condition or restriction does not amount to punishment if it is reasonably related to a legitimate governmental objective (such as institutional security or orderly administration); if arbitrary or purposeless, punitive intent may be inferred.
- Courts should accord substantial deference to correctional officials’ good-faith judgments about policies needed to maintain order, discipline, and security.
- The Fourth Amendment reasonableness of detention searches requires balancing the scope of the intrusion, the manner and place of the search, and the justification for initiating it; significant institutional security interests can justify suspicionless visual searches after contact visits.
- Restrictions on detainees’ receipt of books and packages may be upheld as content-neutral, reasonable measures tied to contraband control and institutional security.

## Conclusion

The Court held that conditions of pretrial confinement violate due process only when they constitute punishment, and it upheld a range of restrictive and invasive MCC practices as reasonable security and administrative measures entitled to substantial judicial deference.


Bell v. Wolfish, 441 U.S. 520 (1979)