In the case of Pamela Withrow v. Robert Allen Williams, Jr., 1992, the U.S. Supreme Court ruled that a prison inmate's Fourth Amendment rights were not violated by a policy allowing officials to conduct random body cavity searches without requiring reasonable suspicion. The court held that maintaining security and order in prisons justified such intrusive searches under certain circumstances. Inmate Robert Allen Williams had argued that these strip searches were unconstitutional as they violated his right against unreasonable search and seizure protected by the Fourth Amendment. However, Justice O'Connor writing for the majority stated that while prisoners do not lose all constitutional protections once incarcerated, their rights may be diminished by considerations of institutional security and internal order.

In the dissenting opinion for Withrow v. Williams, Justice O'Connor, joined by Chief Justice Rehnquist and Justices Scalia and Thomas, argued that the majority's decision to apply a "knowing and voluntary" waiver standard retroactively was incorrect. They contended that this new rule should not be applied to cases on collateral review because it did not meet the criteria set forth in Teague v. Lane (1989) which states that new constitutional rules of criminal procedure will not be applicable to those cases which have become final before the new rules are announced. The dissenters believed there was no evidence suggesting that such a rule would improve accuracy in conviction or sentencing; therefore it didn't possess significant enough value to warrant its retroactive application under Teague’s second exception.