Judge Jesse Furman
Israel entered New York City Department of Correction custody after his arrest for misdemeanor assault. His pro se 42 USC §1983 action alleged Fourth Amendment rights violations stemming from strip searches while in the receiving room of the Manhattan Detention Center as well as a strip search conducted in conjunction with a search of his cell at Riker’s Island. The court granted the city defendants’ unopposed motion for summary judgment. Israel’s claims failed as a matter of law in light of the U.S. Supreme Court’s 2012 ruling in Florence v. Board of Chosen Freeholders that a suspicionless strip search of a detainee arrested for a non-serious crime, conducted prior to introduction into the general jail population, was reasonable and consistent with the Fourth Amendment. Moreover, Israel’s strip searches were reasonably related to legitimate security interests, including prevention of the smuggling of contraband. The Riker’s strip search also was consistent with city policy expressly permitting correction officers to strip search inmates “prior to the search of an inmate’s living quarters [so as] to ensure that the inmate is not concealing contraband on his/her person.”
