In the 1983 case Block, Sheriff of the County of Los Angeles, et al. v. Rutherford et al., inmates at a county jail in Los Angeles filed a class-action lawsuit against the sheriff and other officials for violating their constitutional rights by implementing certain security measures including random cell searches without probable cause, prohibition on receiving packages from outside sources except for legal materials or publications directly from publishers or bookstores, and not allowing contact visits with family members or friends. The District Court ruled in favor of the inmates but was reversed by the Ninth Circuit Court of Appeals which held that these practices were unconstitutional under Fourth Amendment protections against unreasonable search and seizure as well as Fourteenth Amendment due process rights. However, when appealed to Supreme Court it overturned this decision ruling unanimously (9-0) that these restrictions did not violate any constitutional rights because they were reasonably related to legitimate penological interests such as maintaining order within jails and preventing smuggling contraband items into prison facilities. It concluded that courts should defer to professional judgment of correctional administrators unless there is substantial evidence showing an exaggerated response to those objectives.

In the dissenting opinion of Block v. Rutherford, Justice Brennan, joined by Justices Marshall and Blackmun, argued that the majority's decision failed to adequately consider the rights of pretrial detainees. They contended that these individuals should not be subjected to conditions or restrictions more severe than those necessary for their detention or to manage the facility they are held in. The dissenters believed that random cell searches without inmates present and a ban on contact visits were such unnecessary measures. They emphasized that pretrial detainees have not been convicted and thus retain at least some constitutional protections against punishment; therefore, any restriction must be reasonably related to a legitimate governmental objective like security rather than being used as punishment itself. In this case, they felt there was insufficient evidence showing these policies significantly contributed towards jail security.