The U.S. Supreme Court case Bell, Attorney General, et al. v. Wolfish et al., 1978 revolved around the conditions and practices at the Metropolitan Correctional Center (MCC), a federal short-term custodial facility in New York City. Inmates filed a lawsuit claiming that several of MCC's practices violated their constitutional rights under the First, Fourth, Fifth, Sixth and Eighth Amendments. The contested practices included double-bunking inmates due to overcrowding issues; conducting body-cavity searches after contact visits with people from outside; prohibiting inmates from receiving packages containing food or personal property unless it came directly from a publisher or manufacturer; limiting reading material to three books or magazines excluding legal materials and religious texts; enforcing restrictions on inmate law libraries access among others. The court ruled in favor of MCC officials for most claims except one related to punitive measures without due process protections for pretrial detainees who were found guilty by prison disciplinary committees of serious misconduct charges while incarcerated at MCC.

In the dissenting opinion for Bell v. Wolfish, Justice Thurgood Marshall argued that pretrial detainees should not be subjected to conditions or restrictions more severe than those necessary to ensure their presence at trial. He believed that the majority's decision failed to recognize this principle and instead treated pretrial detainees as convicted prisoners serving a sentence. This, he said, was in violation of due process rights under the Fifth Amendment. Furthermore, he disagreed with upholding body cavity searches after contact visits because they were degrading and humiliating without being reasonably related to security interests within prisons. He also objected against double-bunking (two inmates sharing one cell), arguing it could potentially lead to violence and tension among inmates while failing to provide them with minimal civilized living conditions.