Commonwealth v. Gilmore
In Commonwealth v. Gilmore, 27 Va. App. 320, 498 S.E.2d 464 (1998), Gilmore was forced to remove all her clothing in preparation for a "strip search."
The police then conducted a body cavity search.
In finding Gilmore's Fourth Amendment rights were violated, we concluded that "the authority of the police under the Fourth Amendment to conduct a 'full search' of an arrestee's person without a warrant is only skin deep." Id. at 328, 498 S.E.2d at 468.