Does a strip search conducted by female guards violate a prisoner's privacy right?

We have recognized that frequent strip searches serve a legitimate penological purpose so long as a prisoner has any opportunity to obtain contraband or a weapon outside his cell. Michenfelder v. Sumner, 860 F.2d 328, 332-33 (9th Cir.1988) (searches when entering and leaving cells not excessive even if prisoner escorted from one portion of a unit to the next). Similarly we have also concluded that a visual strip search of male prisoners by female guards, without more, does not violate a privacy right. Id. at 334. Because Fain's own allegations establish an opportunity to obtain contraband and only incidental exposure to female officers, the district court did not err.

Handcuffs