"[9] Writing for a five-justice majority, Chief Justice Burger held that summary judgment was appropriate against Palmer on both his due process and Fourth Amendment claims.

"[12] Based on Bell v. Wolfish, where the Court had previously upheld a federal policy of conducting body-cavity searches of pretrial detainees after every visit with someone outside the facility,[13] Burger reasoned that restricting prisoners' Fourth Amendment protections is not problematic because "it is clear that imprisonment carries with it the circumscription or loss of many significant rights.

"[15] This expanded the holding of Parratt v. Taylor, in which the Court held that state tort remedies available after the fact were sufficient due process when a prison official negligently lost an inmate's hobby kit.

"[19] She argued further that the destruction of Palmer's property only raised due process claims, not Fourth Amendment issues, because it "had no bearing on whether the search and seizure were reasonable.

"[22] Although Stevens agreed that the need for prison security makes it legitimate for correctional officers to randomly search inmates' cells, he argued that safety concerns do not eliminate all civil rights of prisoners and that Palmer's Fourth Amendment rights had been violated in this case because the personal materials destroyed by Hudson had been found not to be dangerous.

"[24] Finally, the dissenters disagreed with Chief Justice Burger's assessment that society would not recognize privacy rights for prisoners as legitimate.

[31] In 2012, the Supreme Court cited Hudson v. Palmer in Florence v. Board of Chosen Freeholders of County of Burlington, where it held that strip searches of pretrial detainees entering a general jail population do not violate the Fourth Amendment.