R v Golden, 2001 SCC 83 is a landmark decision of the Supreme Court of Canada on limitations to the power of police officers to perform strip searches.

[5][6][7] On January 18, 1997, the Metropolitan Toronto Police Force set up an observation deck across from a Subway shop, in an area drug trafficking was known to occur.

The officers then escorted him to a seating booth at the back of the lobby, where they forced him to bend over, and then lowered his pants and underwear to his knees.

His application was denied and he was subsequently found guilty by a jury for possession of a narcotic for the purpose of trafficking, but acquitted on the assault charge.

In reaching the decision, the Court found that purpose of section 8 is to prevent unjustified state intrusions into the privacy of individuals, and that it was important to stop unconstitutional searches before they happened instead of just declaring their unlawfulness after the fact.

[12] The Court also established a set of criteria to assess the reasonableness of individual strip searches under the final branch of the section 8 analysis.

The OIPRD found that nearly 40% of all arrests made by the TPS resulted in a strip search, a rate 40 times higher than that of other comparable police forces in Ontario.

[14] After the report, the service overhauled its procedures, established new mandatory training, and set up a process to record, monitor, and audit all strip searches.

As a result of the changes, Interim Toronto police chief James Ramer stated, "Clearly, we were doing it wrong, and changes needed to be made” and said that he expected the number of strip searches to drop further as improvements continued to be implemented.