Hudson v. Palmer

Russell Palmer (plaintiff) was incarcerated in a Virginia prison. A prison guard, Ted Hudson (defendant), randomly searched Palmer’s cell. Palmer alleged that the search was intended to harass him and that Hudson intentionally destroyed some of Palmer’s permitted personal items. Hudson supposedly found a ripped pillowcase in Palmer’s trash can, but Palmer claimed this was a false claim that was also intended to harass him. Palmer was required to pay a fine for having destroyed state property. Palmer sued Hudson in federal district court under 42 U.S.C. § 1983, alleging that (1) Hudson’s search was unreasonable and violated Palmer’s Fourth Amendment rights because it was intended to harass Palmer rather than for a legitimate purpose and (2) Hudson’s destruction of Palmer’s personal property unlawfully deprived Palmer of this property without due process. The district court granted summary judgment to Hudson. The United States Court of Appeals for the Fourth Circuit affirmed the judgment on the property-destruction claim but vacated the judgment on the unreasonable-search claim. The Fourth Circuit ruled that prisoners had a limited privacy right to their cells, a search for the purpose of harassing a prisoner violated that right, and a prison must conduct warrantless searches in accordance with some sort of preset plan in order to avoid the risk of guards using random searches to harass prisoners. The United States Supreme Court granted certiorari.