Hughes v. Commonwealth
In Hughes v. Commonwealth, 31 Va. App. 447, 524 S.E.2d 155 (2000) (en banc), the Court said:
A search of the person may range from a Terry-type pat-down to a generalized search of the person to the more intrusive strip search or body cavity search.
"A strip search generally refers to an inspection of a naked individual, without any scrutiny of his body cavities. A visual body cavity search extends to a visual inspection of the anal and genital areas." Commonwealth v. Thomas, 429 Mass. 403, 708 N.E.2d 669, 672 n.4 (1999).
"A 'manual body cavity search' includes some degree of touching or probing of body cavities." Cookish v. Powell, 945 F.2d 441, 444-45 n.5 (1st Cir. 1991). Id. at 455, 524 S.E.2d at 159.
Hughes was forced to disrobe and the police inspected his underwear.
The Court characterized that activity as a "strip search."