In Block v. Rutherford, U.S. 104 S.Ct. 3227, 82 L.Ed.2d 438 (1984), the Court reiterated that the due process clause forbids punishment of a pre-trial detainee since such individuals have not been judged guilty of a crime. See U.S. at 104 S.Ct. at 3230. The Supreme Court held that the jail's policy did not constitute punishment for purposes of due process analysis. See id. at 104 S.Ct. at 3233-34. The Court first noted that the district court had not found "that the purpose of petitioner's policy of denying contact visitation is to punish the inmates." Id. at 104 S.Ct. at 3232. The Court therefore inquired as to whether the rule was reasonably related to the security of the jail. Given the security problems posed by contact visitation, the Court concluded that the rule was reasonably related to the security of the jail. See id. Finally, the Court rejected the conclusions of the district court and the court of appeals that totally disallowing contact visits was "excessive in relation to the security and other interests at stake" at the jail. Id. The Court emphasized "that we are unwilling to substitute our judgment on these difficult and sensitive matters of institutional administration and security for that of 'the persons who are actually charged with and trained in the running' of such facilities." Id. at 104 S.Ct. at 3233. The Court held that the district court had "simply misperceived the limited scope of judicial inquiry under Wolfish. When the district court found that many factors counseled against contact visits, its inquiry should have ended." Id.