Katz v. United States, 389 U.S. 347 (1967), was a landmark decision of the U.S. Supreme Court in which the Court redefined what constitutes a "search" or "seizure" with regard to the protections of the Fourth Amendment to the U.S. Constitution. The ruling expanded the Fourth Amendment's protections from an individual's "persons, houses, papers, and effects", as specified in the Constitution's text, to include any areas where a person has a "reasonable expectation of privacy". The reasonable expectation of privacy standard, known as the Katz test, was formulated in a concurring opinion by Justice John Marshall Harlan II. The Katz test has since been used in numerous cases, particularly because of technological advances that create new questions about privacy norms and government surveillance of personal data.
The Supreme Court noted that § 46-5-105, MCA, was a spurred by the U.S. Supreme Court’s holding in Florence v. Bd. Of Chosen Freeholders of Cty. of Burlington, 566 U.S. 318 (2012), that misdemeanour arrestees could not be strip searched without reasonable suspicion if they are not placed in the jail’s general population.
