Katherine Reynolds v. City of Anchorage, Leslie Watson, Jefferson County Officer

In holding that Officer Watson’s war-rantless strip-search of a seventeen-year-old girl was “reasonable” under the Fourth Amendment, the district court relied on the “special needs” exception to the rule that all warrantless searches are presumptively unreasonable. In affirming that dubious holding, the majority untethers the *368district court’s language from its reasoning, and in a single paragraph of analysis, relies on United States v. Knights, 534 U.S. 112, 121, 122 S.Ct. 587, 151 L.Ed.2d 497 (2001), to conclude that “reasonable suspicion” is all that is necessary to justify a strip-search…