Hudson holding effectively overrules Bell by rendering all Fourth Amendment claims by inmates non-eognizable. Plaintiffs argue that Hudson is limited to cell searches and does not, therefore, disturb Bell. The parties’ arguments bring into focus the distinction between cell searches and strip searches in custodial facilities. In Hudson, the Court considered a cell search challenged by a convicted inmate and questioned whether the inmate had a reasonable expectation of privacy in his cell which would entitle him to Fourth Amendment rights. Hudson, 468 U.S. at 522, 104 S.Ct. 3194. The Court concluded that 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 in 989) (<HOLDING>); Covino v. Patrissi, 967 F.2d 73, 78 (2d
holding that governments asserted interest in protecting the privacy of arrestees is substantial under central hudson holding that incarcerated prisoners have fourth amendmentprotected privacy interests after hudson and despite hudsons broad language recognizing that violation of privacy right even without objective harm is still compensable holding that even after hudson the prisoners privacy interest in the integrity of his own person is still preserved under bell holding that under article i section 9 a person has no constitutionally protected privacy interest in abandoned property