State v. Jenkins
In State v. Jenkins, 82 Conn. App. 111, 842 A.2d 1148 (2004), where the Connecticut intermediate appellate court "had occasion to address the appropriateness of a strip search incident to a felony arrest." Id. at 591.
In Jenkins, an officer performed a strip search incident to the arrest of appellant who was attempting to sell him heroin.
Faced with a Fourth Amendment challenge to the strip search, the court applied the Bell factors and "explained that the officer had reason to believe that the defendant was carrying contraband because the officer was meeting the defendant presumably to buy heroin." Id. at 592 (citing Jenkins, 842 A.2d at 1157).
The Jenkins Court also noted that "the nature of the offense for which the defendant was arrested created the suspicion necessary to justify the strip search. Based on those factors, the court found that reasonable suspicion existed to conduct the search of the defendant; therefore, the search was reasonable." Id. (citing Jenkins, 842 A.2d at 1157-58).