Alexander v. Connor

In deciding whether in-prison search violates Fourth Amendment, court considers: (1) scope of particular intrusion; (2) manner in which it is conducted; (3) justification for initiating it; and (4) place in which it is conducted; genuine issue of material fact as to whether correctional officers’ purported use of force against inmate—including slamming him to ground, forcing him on to his stomach, and handcuffing him, and then grabbing his hair and yanking his head back and forth, and violently pulling contraband phone out of his rectum in prison shower—was reasonable and justified by reasonably perceived threat to officers precluded summary judgment in action alleging that officers’ actions violated Eighth Amendment.