Whether the court below erroneously held that the physical delousing of all detainees entering the Cleveland Workhouse, whereby delousing solution was sprayed onto the genitals and anus of naked pre-trial detainees with a pressurized spray canister, was constitutional under the Fourth Amendment given reasonable de minimis alternatives to this procedure, including self-application of the solution.

Whether the court below erroneously held that routine group strip searches and physical delousing of all detainees entering the Cleveland Workhouse, whereby detainees were strip searched and deloused in groups of three, were constitutional under the Fourth Amendment given reasonable de minimis alternatives to this procedure, including the utilization of privacy partitions recommended by state regulators.

Whether the physical delousing and group strip searches of detainees entering the Cleveland Workhouse were constitutional under the Fourth Amendment, given reasonable alternatives