In Paulino v. State, 399 Md. 341, 924 A.2d 308 (Md.), cert. denied, 128 S. Ct. 709, 169 L. Ed. 2d 571 (2007), police searched the defendant in a car wash, the Court of Appeals of Maryland held a body search unreasonable due to "the location of the search and the lack of exigency." Id. at 317. In Paulino, a confidential informant told a police detective that the defendant possessed drugs, the manner in which he concealed the drugs, and the defendant's location. Police arrived at the defendant's location, a well lit car wash, lifted up the defendant's shorts, spread his buttocks and retrieved the drugs. Although twelve police officers were present, no attempt was made to transfer the defendant to a police facility prior to the search. Id. at 310-12. In Paulino v. State, the police conducted the search of the suspect in the bay of a brightly lit carwash, in front of at least his cosuspects. Moreover, he was placed prone on the ground, and his buttocks were spread open to allow a better view of his anal cavity. It was the manipulation of his intimate body parts, along with the lack of any evidence that his privacy was protected in any way, that led the Court to hold that the search was both a strip search and a visual body cavity search and unreasonable. The Court stated, however, that if the officers had seen the drugs "without spreading his buttocks cheeks," the search might have been classified as a permissible "reach-in" search. Id. at 353-54. In Paulino, police found drugs between Paulino's buttocks. Id. at 346-47. Ultimately, the Court of Appeals held that "the search of Paulino unreasonably infringed on his personal privacy interests when balanced against the legitimate needs of the police to seize the contraband that Paulino carried on his person." Id. at 361. With respect to the scope factor, an officer that searched Paulino described the search as follows: Detective Latchaw: Well, when we -- when Mr. Paulino was removed from the vehicle and laid on the ground, his pants were already pretty much down around his -- below his butt . . . so it was just a matter of lifting up his shorts, and -- and between his butt cheeks the drugs were -- I believe one of the detectives actually put on a pair of gloves and just spread his cheeks apart a little bit and it was right there. Defense Counsel: So they were not visible before you actually spread his cheeks apart, is that correct? Detective Latchaw: I don't think they were. Id. at 346. Paulino offered a different version of the scope of search: Mr. Paulino: They had searched me in my pockets, didn't find nothing, and eventually, they came to the subject where?in my report, it states that the officer said, Mr. Paulino, why is your butt cheeks squeezed? And in further response, I said nothing. He said it again, and another officers come behind with gloves and pulled my pants down and went in my ass. Well, my cheeks. Sorry about that. Id. On appeal, Paulino argued that "the scope of the intrusion involved in the search of his person was great," as he had to "suffer the indignity of having an officer view his naked body" and had to "endure the humiliation of having an officer physically manipulate his buttocks." Id. at 355-56. The Court of Appeals agreed, holding that "the police officers' search of Paulino was highly intrusive and demeaning." Id. at 356. Turning to the location and manner factors, the Court in Paulino noted that the search was conducted at night in a well-lit parking lot of a car wash within plain view of people who were not involved in the search itself. Id. at 360. The fact that members of the public were present was crucial in the Court's conclusion that the search location was illegal: It is the presence of members of the public, whether their view was obscured or otherwise, that makes the search of Paulino unnecessarily within the public view and thus violative of the Fourth Amendment. Id. The State in Paulino described the justification for the search of Paulino as follows: ". . . the police had sufficient cause to believe that the illegal narcotics Paulino was known to be possessing were actually being concealed in that place." Id. at 356. The police had arrested Paulino pursuant to information provided by an informant. Id. at 344. The informant had told the police that Paulino would be at a certain location in Dundalk, Maryland that evening, and would be in possession of a quantity of controlled dangerous substance. Id. "The informant also advised the police that Paulino typically hides the controlled dangerous substance in the area of his buttocks." Id. Ultimately, the Court of Appeals in Paulino concluded that "the police officers were justified in initiating the search of Paulino," but that the officers were not justified in "searching him to the extent he was searched under the circumstances." Id. at 357. In sum, police received a tip from a confidential informant that Paulino would be at a particular location, that he would have in his possession a quantity of a controlled dangerous substance, and that "Paulino typically hides the controlled dangerous substance in the area of his buttocks." Id. at 344. When Paulino pulled into a car wash bay, the police removed him from the vehicle. Wearing gloves, they "lifted up his shorts," spread his butt cheeks, and discovered cocaine. Id. at 346. The Paulino Court classified that search as "both a strip search and a visual body cavity search" because "the drugs were not visible until after the cheeks of Paulino's buttocks were spread apart." Id. at 353 - 54. In addressing the reasonableness of the search, the Court looked to the United States Supreme Court's decision in Bell v. Wolfish, 441 U.S. 520 (1979), for "the appropriate test" to determine "the reasonableness of a search." Id. According to the Paulino Court, all searches that "entail the inspection of the anal and/or genital areas have been accurately described as demeaning, dehumanizing, undignified, humiliating, embarrassing, repulsive, degrading, and extremely intrusive of one's personal privacy." Paulino, 399 Md. at 356 (citing Amaechi v. West, 87 F.Supp.2d 556, 565 (E.D. Va. 2000), aff'd, 237 F.3d 356 (2001)). In considering the scope of the search, the Court concluded that "the police officers' search of Paulino was highly intrusive and demeaning." Id. The Court emphasized that the issue was "not whether the police had the right to search Paulino, but instead whether an exigency existed such that an invasive search, conducted at the scene of the arrest, was reasonable." Id. at 357. Because the police had made no "attempt to limit the public's access to the car wash or to take any similar precaution that would limit the ability of the public or any casual observer from viewing the search of Paulino," the search was determined to be unreasonable. Id. at 357-58.