Raiche v. Pietroski

What Happened

Matthew Raiche was arrested on a misdemeanor charge in Springfield, Massachusetts. At the police station, Officer Jamie Pietroski conducted an invasive visual strip search of Raiche — ordering him to remove all clothing, bend over, and spread — despite having no reason to believe Raiche was hiding weapons or contraband. The charge was a minor offense that did not typically warrant such an intrusive search. Raiche filed a § 1983 action alleging the strip search violated his Fourth Amendment rights.

What the Court Said

The First Circuit ruled that the strip search was unconstitutional under the Fourth Amendment. The court held that strip searches of arrestees at a police station require at least reasonable suspicion that the individual is concealing weapons or contraband, particularly for minor offenses. Critically, the court also found that this right was clearly established at the time of the search, meaning Officer Pietroski could not hide behind qualified immunity. The case was allowed to proceed to trial.

Why This Case Matters

Raiche v. Pietroski is an important First Circuit precedent for anyone who has been subjected to a degrading strip search by police. With 148 citations, it establishes a clear rule: police cannot strip search someone arrested for a minor offense without specific reason to believe they’re hiding something. For pro se litigants in Massachusetts and the First Circuit, this case is especially valuable because the court defeated qualified immunity — showing that courts take illegal strip searches seriously and that officers should know better. If you were strip-searched at a police station without justification, this case is strong authority for your § 1983 claim.