Bell v. Wolfish

The Metropolitan Correctional Center (the center) was a jail built in 1975 with the intention of housing primarily pretrial detainees. The center had 389 rooms, most of which were designed to house only one inmate, and a total planned capacity of 449 inmates. Soon after the center was built, however, the number of pretrial detainees rose significantly, and overcrowding became a problem. Double bunks were installed in the single-occupancy rooms and new arrivals were housed on cots in common areas until bunk space became available. The center also subjected all inmates, both pretrial detainees and those who had been convicted and sentenced, to restrictions on receipt of packages, body cavity searches, and a requirement that inmates stay outside their rooms while center officials conducted inspections. Louis Wolfish (plaintiff), on behalf of all inmates at the center, brought a federal class-action lawsuit challenging many of the center’s practices. The district court enjoined the center from engaging in twenty of the practices complained of by the inmates. The court of appeals largely affirmed the district court’s ruling, holding that pretrial detainees may be subject only to those conditions necessary to ensure their appearance at trial and that are justified by compelling necessities of jail administration. The United States Supreme Court granted certiorari.