with whom CANBY, Circuit Judge, joins, concurring:
Eldon Vail is the superintendent of the Washington Corrections Center for Women. The prison employs both male and female guards.1 Superintendent Vail has authorized the male guards (as well as the females) to search the clothed bodies of the female inmates randomly and routinely, using a “grab-type motion” to “rub,” “strokfe], squeez[e],” and “knead[j” the women’s exteriors, including their covered breasts, buttocks, inner thighs, and crotches. The guards are told to “push inward and upward” when searching the women’s upper thighs and crotches and to check the crease in their buttocks with a downward motion of the edge of the hand. There is no dispute that the searches are necessary; the question is whether, under the Constitution, male guards may perform them.
Prison regulations prohibit male guards from conducting strip searches and body cavity searches. However, Superintendent Vail contends that the prison’s security will be compromised if male guards are prohibited from conducting the clothed body searches as well. He also contends that the rights of both the male and female guards to equal employment opportunities and to the full benefits of their collective bargaining agreement will be adversely affected if the male guards are not permitted to perform their share of those searches. The female inmates urge that cross-gender clothed-body searches are invidious and violate their rights under the first, fourth, and eighth amendments. They contend that clothed body searches may be performed only by female guards. The district judge agreed with each of the inmates’ constitutional arguments.
I.
The majority decides this case on the basis of the eighth amendment. I believe that the conduct challenged here violates the fourth amendment as well as the eighth, and that this case is more properly decided on the basis of the former constitutional protection. The question of which constitutional provision to rely upon when an act violates more than one is, however, a prudential matter. Here, a majority supports the proposition that the eighth amendment has been violated, but a number of its members do not wish to reach the fourth amendment question. While I would prefer to rely on the fourth amendment and believe strongly that the court should do so, I agree fully with Judge O’Scannlain’s reasoning and conclusion that these searches violate the eighth amendment. Accordingly, I join his opinion, with the exception of Part II.2 In the discussion that follows, I analyze this case under the fourth amendment. I set out my reasons for relying on that amendment in Part V, infra.
II.
Washington Corrections Center for Women, a state prison for women, in Gig Harbor, Washington, opened in 1971. Prior to July, 1989, male guards at the prison did not actually conduct searches of the female inmates. While under the regulations male guards were permitted to conduct “suspicion searches”—to search an inmate’s clothed body if they had reason to suspect that the woman was carrying contraband or if there were an emergency— suspicion searches were, in practice, always conducted by female guards. The prison regulations also permitted “suspicionless searches,” but the regulations expressly stated that those searches were to be conducted by female guards only. Until July, 1989, only one type of suspicionless search was authorized, “routine searches.” Routine searches were performed (by female guards) at fixed checkpoints, such as the kitchen or the visiting room. In July, 1989, *1533Eldon Vail, the new superintendent of the prison, authorized guards to begin conducting a second type of suspicionless search called “random searches.” Under the policy establishing random searches, no cause is required for the search and no fixed locations are provided for. The policy calls for guards to search a minimum of ten inmates per shift at random during the day and swing shifts; searches may be conducted anywhere in the general prison area or in any part of the women’s cells themselves; unlike routine searches, there is no advance notice that a random search will be conducted.
When Superintendent Vail issued the policy providing for random searches, he authorized male as well as female guards to conduct them, and he also, for the first time, authorized male guards to conduct routine searches. After the superintendent’s actions, as of July 5, prison policy authorized all guards to conduct both “suspicionless” and “suspicion” searches. However, as the majority points out, this policy lasted only one day, following which, first by agreement and then by injunction, the authority' of male guards to conduct suspicionless searches was suspended. Although no injunction was sought with respect to suspicion searches, the prior practice of having those searches conducted by female guards only continued in effect.3
Superintendent Vail was prompted to issue his new policy by a grievance from the guards’ union that challenged the prison’s assignment of routine (suspicionless) searches to female guards alone.4 In the past, prison administrators had denied similar grievances because they believed that the single-sex searches were “consistent with ... prudent correctional management.” Superintendent Vail testified that when he made his decision to allow cross-gender searches, he was in a “lose/lose” situation. If he turned down the grievance, the guards would sue; if he authorized male guards to conduct the searches, the inmates would sue.5
Prison administrators call the cross-gender clothed body searches “pat searches.” The district court refused to adopt the prison’s term, wisely in my view. According to the prison’s training materials, the proper way to conduct such a search is to
Squeeze and knead the shoulders____Knead ... the inside of the waistband of trousers [and] pull[ ] the fly away from the body. From behind, ... [use] both hands across the crotch[,] [p]ushing the hands across the crotch[,] [squeezing and kneading all seams____ The breast area shall be searched in a sweeping motion, using only the back of the hand____ The breasts of a female will be flattened by this method. Use a flat hand and a pushing motion across the crotch area. Maintain a flat, inward pushing motion. The edge of the hand in a downward motion can be used to check the crease in the buttocks. Push inward and upward when searching the crotch and upper thighs of the inmate.
Washington Corrections Center for Women, Pat-Down Searches of Female Inmates. While some modifications to the procedure may have occurred, the descriptions by the prison personnel and inmates, the training material, and a videotape viewed by this court reveal that the searches involve nothing so delicate or so tentative as “patting.” Rather, the searches are intimate and deeply invasive.
*1534Male guards conducted the intrusive suspicionless searches on July 5, 1989. After an inmate was searched by a male guard, her fingers had to be pried from the bars she had grabbed; she returned to her cell-block, vomited, and broke down. As soon as the searches began, the inmates filed a pro se complaint in district court. The prison informally agreed to suspend them that same day. Two days later, when the superintendent decided to reinstitute the searches, the inmates obtained a temporary restraining order. They subsequently obtained a preliminary injunction and were certified as a class. After a six-day trial, the district court entered a permanent injunction barring cross-gender suspicionless clothed body searches.6 The state appealed.
III.
I believe that invasive cross-gender searches violate the fourth amendment rights of female prisoners. Persons who have been convicted of crimes do not forfeit all of their rights under the Constitution when they pass through the gates of a prison. No "iron curtain" separates prison inmates from constitutional protections, Wolff v. McDonnell, 418 U.S. 539, 555, 94 S.Ct. 2963, 2974, 41 L.Ed.2d 935 (1974); rather, inmates retain "those rights not fundamentally inconsistent with imprisonment itself or incompatible with the objectives of incarceration." Hudson v. Palmer, 468 U.S. 517, 523, 104 S.Ct. 3194, 3198, 82 L.Ed.2d 393 (1984) (plurality opinion). Prisoners may not be subjected to invidious racial discrimination, Lee v. Washington, 390 U.S. 333, 88 S.Ct. 994, 19 L.Ed.2d 1212 (1968) (per curiam); they may petition the government for a redress of grievances, Johnson v. Avery, 393 U.S. 483, 89 S.Ct. 747, 21 L.Ed.2d 718 (1969); they may not be denied access to the courts, Bounds v. Smith, 430 U.S. 817, 97 S.Ct. 1491, 52 L.Ed.2d 72 (1977); they are entitled to due process of law, Wolff v. McDonnell, supra; and they may not be subjected to cruel and unusual punishment, Hudson v. McMillian, — U.S. —, 112 S.Ct. 995, 117 L.Ed.2d 156 (1992).
Of more particular concern here, prison inmates have a right of privacy and dignity in their persons.7 Although the Supreme Court has held that prisoners have no right to privacy in their cells, Hudson v. Palmer, supra (plurality opinion), the limitation on privacy rights has not been extended to searches of prisoners’ bodies. See id., 468 U.S. at 555 n. 31, 104 S.Ct. at 3215 n. 31 (Stevens, J., concurring in part and dissenting in part). Following Hudson v. Palmer, courts, including ours, have consistently held that the fourth amendment applies to searches of prisoners themselves. See, e.g., Cornwell v. Dahlberg, 963 F.2d 912, 916-17 (6th Cir.1992) (male inmate strip-searched before female guards raises a valid fourth amendment privacy claim); Michenfelder v. Sumner, 860 F.2d 328 (9th Cir.1988) (visual body cavity searches of inmates do not violate fourth amendment); Bonitz v. Fair, 804 F.2d 164 (1st Cir.1986) (fourth amendment right to be free of body cavity search overcomes claim of qualified immunity). The parties do not dispute that the fourth amendment is implicated in this case.
In Turner v. Safley, 482 U.S. 78, 107 S.Ct. 2254, 96 L.Ed.2d 64 (1987), the Supreme Court established the general stan*1535dard for evaluating prisoners’ constitutional claims, including fourth amendment claims.8 Turner distills the principles originally established in Bell v. Wolfish, 441 U.S. 520, 551, 99 S.Ct. 1861, 1880, 60 L.Ed.2d 447 (1979), and a series of related cases.9 Turner summarizes the standard that emerged from these cases as follows: "when a prison regulation impinges on inmates’ constitutional rights, the regulation is valid if it is `reasonably related’ to legitimate penological interests [and is not] an `exaggerated response’ to those concerns." Turner, 482 U.S. at 87, 107 S.Ct. at 2260-61, 96 L.Ed.2d 64 (1987). Turner also identifies four factors that should be considered when determining whether this standard is met: first, whether there is "a `valid, rational connection’ between the prison regulation and a neutral, legitimate government interest put forward to justify it"; second, whether there are alternative means of exercising the asserted constitutional right that remain open to the inmates; third, whether and to what extent accommodation of the asserted right will have an impact on prison staff, inmates, and the allocation of prison resources generally; and, fourth, whether a ready alternative to the challenged practice exists that will fully accommodate the prisoner’s rights at de minimis cost to valid penological interests. Id., 482 U.S. at 89-91, 107 S.Ct. at 2262.
The four factors must be evaluated in light of the Court’s overarching task: to determine whether a prison’s policy is reasonably related to prison administrators’ valid concerns or is an exaggerated response to those concerns. Under Turner, a prison’s response to its penological concerns must be appropriate: it must be reasonable; it cannot stand if it constitutes an overreaction.
The Turner factors must be applied in light of the type of constitutional violation involved and the circumstances of the particular case. Some weigh more heavily in some circumstances; others more heavily in others.10 We derive guidance as to how the Turner factors are to be applied in “unreasonable search” cases from Bell v. Wolfish, supra. Bell tells us that “[t]he test of reasonableness under the Fourth Amendment is not capable of precise definition or mechanical application.” Bell v. Wolfish, 441 U.S. at 559, 99 S.Ct. at 1884. Instead, Bell mandates a balancing test. It states, “In each case [the test of reasonableness] requires a balancing of the need of the particular search against the invasion of personal rights that the search entails.” Id. (emphasis added). Thus, after applying the four Turner factors and evaluating all the circumstances, we must ask whether the prison’s need to use male guards to conduct the body searches—to the extent that such heed exists—outweighs the constitutional injury resulting from the invasiveness of the intrusion.
In evaluating a claim under Turner, a court must accord "appropriate deference to prison officials," O’Lone v. Estate of Shabazz, 482 U.S. 342, 349, 107 S.Ct. 2400, 2404, 96 L.Ed.2d 282 (1987), because "the judiciary is ill-equipped to deal with the difficult and delicate problems of prison management," Thornburgh v. Abbott, 490 U.S. 401, 407-08, 109 S.Ct. 1874, 1878, 104 L.Ed.2d 459 (1989). This admonition applies especially strongly to concerns over prison security, which, the Court has stated, is the most important of all legitimate *1536correctional goals. Hudson v. Palmer, 468 U.S. at 525, 104 S.Ct. at 3199. While courts must refrain from substituting their judgment for that of prison administrators, Whitley v. Albers, 475 U.S. 312, 322, 106 S.Ct. 1078, 1085, 89 L.Ed.2d 251 (1986), deference "does not mean abdication," Walker v. Sumner, 917 F.2d 382, 385 (9th Cir.1990). "[Turner’s] reasonableness standard is not toothless," Thornburgh v. Abbott, 490 U.S. at 414, 109 S.Ct. at 1882. "[W]hen a prison regulation or practice offends a fundamental constitutional guarantee, federal courts will discharge their duty to protect constitutional rights." Turner, 482 U.S. at 84, 107 S.Ct. at 2259 (internal quotation omitted; citation omitted).
IV.
A.
If the cross-gender clothed body searches authorized by Superintendent Vail are to pass constitutional muster under Turner, there must, first, be a “valid, rational connection between [the cross-gender searches] and the legitimate governmental interest put forward to justify [them].” Turner, 482 U.S. at 89, 107 S.Ct. at 2262 (internal quotation omitted; citation omitted). Prison administrators claim that the security needs of the prison and the employment rights of the guards justify cross-gender searches. As I discuss below, the connection between any legitimate penological interest and cross-gender searches is tenuous.
Turner next requires a court to determine whether alternative means of exercising the constitutional right remain open to the inmates. Id., 482 U.S. at 90, 107 S.Ct. at 2262.11 The prison’s authorization of suspicionless cross-gender searches leaves the inmates no means of protecting their bodies against unreasonable searches. An inmate can do nothing to escape a search. Even an inmate who stays in her cell and behaves impeccably can be forced to submit to a male guard’s search of her body in an offensive, invasive, and intimate way.
The third factor to be addressed under the Turner analysis is “the impact that accommodation of the asserted constitutional right will have on others (guards and inmates) in the prison.” Thornburgh v. Abbott, 490 U.S. at 418, 109 S.Ct. at 1884. “When accommodation of an asserted right will have a significant ‘ripple effect’ on fellow inmates or on prison staff, courts should be particularly deferential to the informed discretion of corrections officials.” Turner, 482 U.S. at 90, 107 S.Ct. at 2262 (citation omitted; emphasis added). Here, there will, of course, be no adverse effect of any kind on other inmates if female guards instead of male guards conduct the body searches, and, as I explain below, there is no evidence that there will be more than a slight impact on the rights of prison staff. The general grousing by the staff reflected in the record is no substitute for facts.
Finally, under Turner, courts must consider whether there is an alternative to the challenged practice that fully accommodates the prisoner’s rights at de minimis cost to valid penological interests. The existence of an “obvious, easy” alternative suggests that the regulation is not reasonable but is an exaggerated response to prison concerns. Id., 482 U.S. at 90-91, 107 S.Ct. at 2262. Here, there is, without question, an obvious, easy alternative to the use of male guards to perform searches which because of their cross-gender nature are highly offensive and intimidating to the female inmates whose bodies are searched: female guards can be used instead. Doing so may require a slight ad*1537justment to guards’ work schedules, but that is a small price to pay for the preservation of the inmates’ fundamental constitutional rights. Almost any accommodation of constitutional rights will result in some “administrative burden”; most accommodations are not “cost-free.” Salaam v. Lockhart, 905 F.2d 1168, 1173 (8th Cir.1990), cert. denied, 498 U.S. 1026, 111 S.Ct. 677, 112 L.Ed.2d 669 (1991). The minor adjustments in the practices of the Washington Corrections Center for Women that the use of female guards would require are relatively insignificant, both in themselves and when weighed against the constitutional interests at stake.
B.
Properly applied, the four Turner factors address the question whether a particular prison policy is reasonable or constitutes an overreaction. To answer that question fully, it is necessary to evaluate carefully both the interests advanced to justify the prison policy and the practical effect of the policy on the inmates’ rights. It is also necessary to examine the force of the connection between the specific provisions of the policy and the underlying problems they are designed to alleviate. Only by assessing these factors is it possible to determine whether the prison’s actions are reasonably related to the interests it advances—to decide whether the connection between the policy and the prison’s interests is reasonable or whether, in light of the effect of the policy upon the prisoners’ constitutional rights, it reflects an overreaction. It is not enough that there are security concerns that may be alleviated to some minor degree by the regulation, or that the warden is acting in good faith and on the basis of his or her experience with the type of problem at hand. While legitimate concerns may justify a restriction, it is the particular restriction that must be justified by the particular problem at hand. For example, in Turner, the Court found that there were legitimate security concerns that justified placing reasonable restrictions upon the right to marry. However, it ultimately concluded that the particular regulation represented an exaggerated response to those security objectives. Turner, 482 U.S. at 97-98, 107 S.Ct. at 2266. Here, there are legitimate concerns that justify suspicionless searches; the question is whether the specific solution of having male guards perform the searches is reasonable. In answering this question, we give all due deference to the knowledge and experience of prison administrators. Id., 482 U.S. at 85, 107 S.Ct. at 2259. Having done so, I conclude that the cross-gender searches and the prison policy authorizing them are clearly “unreasonable.”
(1)
The first interest that prison administrators advance in support of the policy authorizing clothed body searches by male guards is that of institutional security. The officials contend that suspicionless searches serve to suppress the movement of contraband through the prison and that if male guards do not conduct some of the searches, inmates will be able to predict, based on the gender of the guards around them, whether searches will be conducted.
As the majority opinion notes, the district court found that the prison’s security concerns do not justify random and routine cross-gender searches. In fact, the record reveals only a slight penological justification for having' the searches conducted by male guards. With all due respect to the Superintendent, the “predictability” concern on which he primarily relies appears to be highly conjectural.
Superintendent Vail’s written explanation of his reasons for instituting the cross-gender searches are significant. They do not mention “predictability” or the prison’s security needs; they discuss instead “the efficient operation of the institution and ... the adverse impact [of the prohibition of random searches by male guards] on staff and inmate morale. Of equal importance is the fair distribution of employee work duties.” At trial, the superintendent testified, “The beginning of this issue, as I understand it, was that there was a lot of female officers who were simply tired of doing all the searches and the males didn’t *1538do them. They didn’t see that that was fair or equitable.” When Superintendent Vail was asked at his deposition, “Specifically, what security issues again are you responding to in having male officers perform pat searches?” he testified, “I am not responding to a security issue by having male officers perform the pat searches. I’m responding to security issues by moving towards that a pat search is conducted at random locations around the facility. In order to do that and not be in a position where I am open to charges of sexual discrimination, it requires that all officers be allowed to conduct pat searches” (emphasis added). At trial, the Superintendent acknowledged giving the above answer during his deposition. He then added that he thought the statements in his deposition were consistent with his trial testimony.
Further, there are no facts in the record that contradict or undermine the district court’s finding. To the limited extent that Superintendent Vail’s testimony may be said to be contrary to the district court’s conclusions, the testimony is entirely speculative. Superintendent Vail hypothesized, for example, that the advantage of unpredictability would be lost if men were not permitted to conduct random searches: “[I]f an inmate knows that there’s three male officers on that side of the institution, then that’s the time to move the contraband.” This testimony was significantly undermined on cross-examination when the superintendent admitted that inmates would not ordinarily know the sex of the guards “on that side of the institution” until they arrived there, and therefore could not know in advance that “that’s the time to move the contraband.” In addition, an inmate cannot possibly know in advance whether a temporary search location will be set up so that guards may conduct random searches “on that side of the institution.” Even more important, neither Superintendent Vail nor any other prison administrator suggested that single-gender deployment of male prison guards is required by prison security interests or is supported by any other legitimate penological consideration—or even that it would be in any way desirable from an efficiency or other institutional standpoint. Superintendent Vail’s speculation is similar to the type of general assertion regarding security concerns advanced by prison officials in Turner and rejected by the Court. Id., 482 U.S. at 97-99, 107 S.Ct. at 2265-66.12
Moreover, the Superintendent’s reliance on the “predictability” factor proved unfounded. As the record reflects, the prison’s experience while the district court’s preliminary injunction was in effect was that prison security was not impaired in the slightest by the prohibition against cross-gender searches. Superintendent Vail testified at trial that following the issuance of the injunction the prison authorities were able to conduct all the searches he believed necessary using only female guards—and that the searches were conducted at the times and places and in the manner he believed desirable.
In short, the prison’s policy of authorizing male guards to conduct suspicionless searches of the female prisoners is not supportable on the basis of the stated security considerations. Female guards can and do perform those searches just as effectively, and without in any way jeopardizing any of the prison’s security interests. I do not minimize the need of every prison to maintain the security and safety of guards, staff, and inmates. However, “the Supreme Court has repeatedly held that routine and automatic arguments to the effect that 'every step taken to protect constitutional rights of prisoners will lead to a breakdown in institutional discipline and security’ are inadequate to support restrictive prison regulations or policies.” Walker v. Sumner, 917 F.2d at 387 n. 3. (citations omitted). That admonition is particularly appropriate here.
*1539The second interest that the prison administrators advance is that barring male guards from conducting suspicionless searches would require some adjustments of staff schedules and job responsibilities, and the overriding of the bid system in the collective bargaining agreement, possibly leading to litigation by the guards’ union. Minor adjustments of staff schedules and job responsibilities do not constitute the type of administrative burden that justifies overriding constitutional rights; nor does the need to modify a provision of a labor contract. The adjustments pointed to by the prison officials are de minimis indeed. Moreover, as the majority correctly concludes, the guards’ employment rights have not been compromised by the injunction against cross-gender searches. Experience has demonstrated that the bid system and the collective bargaining agreement are not adversely affected. Even prior to the issuance of the injunction, prison policy provided that female guards alone could conduct random urinalyses, strip searches, body cavity searches, and searches of female visitors, and that male guards alone could conduct searches of male visitors. The preliminary injunction against cross-gender searches at the prison did not cause the prison authorities to seek a single BFOQ or to change the job of a single guard as of the time of trial; all that has been required, according to the record, is some adjustments in scheduling and job assignments, adjustments that are no more burdensome than those required from time to time for a variety of other non-penological reasons. Superintendent Vail acknowledged reluctantly that the changes had been made without causing any significant disruptions, and did not suggest any reason that the changes could not remain in effect. The burden on the prison—enlisting the cooperation of the guards’ union, adjusting job responsibilities, calling female officers away from their on-duty meals to perform searches—is minor, and a minor burden must be endured in order to preserve constitutional rights. See Salaam v. Lockhart, 905 F.2d at 1171 (holding required changes in prison policy not burdensome in light of the overall cost of operating the prison).13
(2)
While the prison’s penological interest supporting the regulation is minor, the impact of cross-gender searches on the inmates’ constitutional rights is substantial. The district court found that an unknown number of the women inmates would be greatly harmed if the searches were reinstituted. The district court’s finding is clearly correct.
Most of the inmates at the prison have been physically and sexually abused by male family members or strangers.14 Having male guards rub, squeeze, and knead their bodies is exceedingly harmful to these women. A former clinical psychologist at the prison testified that the intrusive searches could lead to revictimization, anxiety, depression, and possibly increased suicide attempts in women who are survivors of male violence. A psychiatric social worker who worked at the prison testified that the intimate searches presented “al*1540most an unendurable psychological threat and stress” for such inmates. Another clinical psychologist testified that women with histories of personal victimization would likely be revictimized by male guards’ invasive contact with their breasts and genitals, because the guards’ touching was unsolicited and the women were powerless to prevent it.
Furthermore, even the inmates who did not experience the degradation that these inmates recounted would suffer substantial harm if subjected to cross-gender searches. The intrusive, probing searches at issue here permit men in positions of ultimate authority to flatten the breasts of women who are powerless and totally subject to their control, to knead the seams of their clothing at their inner thighs, and to thrust their hands inward and upward into their crotches. Such conduct is offensive in the extreme to all women, regardless of their prior sexual history.
A common-sense understanding of the different experiences of men and women in this society, Ellison v. Brady, 924 F.2d 872, 879 (9th Cir.1991), leads to the inescapable conclusion that invasive searches of the bodies of female prisoners by male prison guards are harmful both because they constitute and reinforce gender subordination, and because they offend our basic values and our concepts of human dignity.
C.
Under the Constitution, searches of prisoners’ bodies, like other limitations on prisoners’ constitutional rights, must be reasonable, and cannot constitute an exaggerated response to a prison’s legitimate goals.
In evaluating the interests that Superintendent Vail has advanced in support of the prison’s policy, we "accord wide-ranging deference" to the superintendent’s judgment that particular "policies and practices . . . are needed to preserve internal order and discipline and to maintain institutional security." Hudson v. McMillian, — U.S. at —, 112 S.Ct. at 999 (citations omitted). No matter how deferentially judged, however, the interests that the superintendent has advanced are insubstantial. They are significantly outweighed by the harm the policy inflicts on the inmates and the injury it does to their constitutional rights. Thus, they fail the Bell v. Wolfish test as applied in light of the four Turner factors.15 If we say that any legitimate penological interest, no matter how minor, requires us to find that a prison’s policy is valid, then we cannot find any policy invalid, because a prison will rarely if ever adopt a policy that lacks even a colorable claim of validity. Rather, a prison policy must be invalidated if, after giving due deference to the knowledge and experience of prison administrators, we find that the constitutional infringement outweighs the prison’s legitimate penological interests. Such is certainly the case here. It is simply not reasonable to have the searches at issue conducted by male guards.
Because the suspicionless cross-gender searches are not “ ‘reasonably related’ to legitimate penological objectives [and] represent ] an ‘exaggerated response’ to those concerns,” Turner, 482 U.S. at 87, 107 S.Ct. at 2261, they violate the fourth amendment. I would uphold the district court’s injunction on the basis of that constitutional violation.
V.
I now address Part II of Judge O’Scannlain’s opinion and explain why I believe that it is more appropriate to base our decision on the fourth amendment than on the eighth. In my view, the Supreme Court’s recent decision in Soldal v. Cook County dictates that approach. Soldal v. Cook County, — U.S. —, 113 S.Ct. 538, 121 L.Ed.2d 450 (1992). In Soldal, the Court considered conduct that could be analyzed under both the fourth amendment and the due process clause. Unanimously *1541reversing a Seventh Circuit decision that looked only to the "dominant character of the conduct challenged," id. — U.S. at —, 113 S.Ct. at 548 (quoting Soldal v. Cook County, 942 F.2d 1073, 1080 (7th Cir.1991) (en banc)), the Court stated that where a wrong "implicate[s] more than one of the Constitution’s commands . . . we examine each constitutional provision in turn." Id. There can be no doubt that the question whether the particular type of search involved here is constitutional implicates the fourth amendment. Judge O’Scannlain’s opinion acknowledges that fact. Majority at 1524. Moreover, no court has held that searches of prisoners’ bodies should be assessed under a different constitutional provision. See supra Part III. However, because the searches at issue here implicate the eighth amendment as well, the question therefore arises as to which amendment, the fourth or the eighth, should constitute the basis for our decision.16
I believe that Soldal requires us to consider the fourth amendment before we consider the eighth. The Soldal Court emphasized the importance of applying "the more `explicit textual source of constitutional protection’ [rather than] the `more generalized notion.’" Id. — U.S. at —, 113 S.Ct. at 548 (quoting Graham v. Connor, 490 U.S. at 394-96, 109 S.Ct. at 1871).17 The conduct at issue in this case "plainly is a `search.’" Majority at 1524. The "explicit textual source of constitutional protection" with respect to "searches" of "persons" is, without doubt, the fourth amendment, not the more general eighth amendment.
The majority argues that the most appropriate basis for examining the challenged searches in this case is the cruel and unusual punishments clause of the eighth amendment, because the searches inflict pain. However, Soldal requires us to look to the fundamental conduct at issue before proceeding, if necessary, to more generalized characterizations of the challenged behavior. Here, the fundamental conduct at issue is a search. The searches of the female inmates, not the pain those searches inflict, is the conduct challenged by the plaintiffs. Similarly, the cross-gender searches, not the infliction of pain, are what the district court’s injunction prohibits. Pain is simply an incident of the unreasonable searches, not, as Judge O’Scannlain would have it, “[t]he gravamen of the inmates’ charge.”18 Majority at 1524-25.
The term “search,” as it is used in fourth amendment jurisprudence, has a specific core meaning.19 Insofar as searches of persons are concerned, the term applies to all such examinations of the individual— pat-down searches, clothed body searches, visual strip searches, visual body cavity searches, and digital body cavity searches—no matter how minimal or how probing they may be. In contrast, the term “cruel and unusual punishment” has no fixed, core meaning. It is a far more general term that is not limited to one type of behavior, but applies instead to a variety *1542of forms of unconstitutional governmental conduct. Under the cruel and unusual punishments clause, courts have analyzed, for example, claims that sentences are unduly harsh or otherwise constitutionally inappropriate,20 claims that inmates have been subjected to physical abuse21 or unlawfully denied medical treatment,22 and claims that conditions of confinement “deny ‘the minimal civilized measure of life’s necessities.’ ”23 Wilson v. Seiter, — U.S. at —, 111 S.Ct. at 2324 (quoting Rhodes v. Chapman, 452 U.S. 337, 347, 101 S.Ct. 2392, 2399, 69 L.Ed.2d 59 (1981)).
The cruel and unusual punishments clause functions in this case in the same way that the due process clause did in Soldal: it is the generalized, not the explicit, notion of constitutional protection implicated by the challenged behavior.24 Similarly, the prohibition of unreasonable searches in this case functions in the same way that the bar against unreasonable seizures did in Soldal: the fourth amendment is the explicit textual source of constitutional protection against the search, as it was against the seizure. A fixed core meaning inheres in the constitutional prohibition of both unreasonable searches and unreasonable seizures; each describes a discrete form of conduct. Because, in my view, the fourth amendment is without question “the more explicit textual source of constitutional protection” against the searches at issue here, I believe that this case should be decided on that basis.
Even without Soldal, logic tells us to consider the fourth amendment first. There is an advantage to simplicity, even in the law. Under the fourth amendment, the legal issue is clear, and the problem is relatively simple. All parties agree that the challenged actions constitute a search; the only question is whether the search is “unreasonable.”25 The determination of reasonableness merely requires the application of objective legal principles. Accordingly, we should not commence with the complex issues posed by an exploration of eighth amendment doctrine.26 Moreover, while no search of prisoners’ bodies could violate the eighth amendment without also violating the fourth, the converse is not true. Thus, in cases involving such searches, an examination of the fourth amendment issue will always be dispositive, while an eighth amendment analysis *1543may prove to be only a precursor to the necessarily duplicative fourth amendment review.27
For the above reasons, I believe we should base our holding on the fourth rather than the eighth amendment.
CONCLUSION
In my view, the prison’s cross-gender clothed body searches violate the fourth amendment. I would uphold the injunction on that ground. However, I also believe the searches violate the eighth amendment. I therefore join in Judge O’Scannlain’s opinion, except for Part II.
. As the institution's name suggests, there are no male inmates at the prison, only females.
. Judge O'Scannlain’s opinion is thus a majority opinion insofar as it relates to the existence of an eighth amendment violation as well as with respect to all matters other than the choice of that amendment rather than the fourth amendment as the proper basis for our holding. Part II of his opinion, dealing with the decision to rely on the eighth amendment rather than the fourth, represents a plurality view only.
.While suspicion searches are not challenged in this action, I suspect that the outcome would be the same—even though the controlling issue might be slightly different; i.e., whether it would be feasible for male guards who develop sufficient suspicion regarding particular inmates either to summon female guards to conduct the searches on the spot or to take the inmates to a post at which a female guard is stationed so that the search may be conducted there.
. At the time the grievance was filed, Superintendent Vail had not yet authorized the second category of suspicionless searches—random searches.
. In an unsuccessful attempt to minimize inmates’ complaints, Superintendent Vail ordered that all random and routine searches, whether performed by male or by female guards, be conducted in the presence of a staff member who was to act as an observer.
. Thus, as of now, male guards do not conduct any body searches of female inmates. See supra page 1532, ¶ 2; page 1533, ¶ 1.
. Judge O’Scannlain states that I fail "to pinpoint precisely which legitimate Fourth Amendment interest is violated by these searches." Majority at 1524. He is sorely mistaken. The precise fourth amendment interest that is violated is "[t]he right of the people to be secure in their persons . . . against unreasonable searches." U.S. Const. amend. IV. Moreover, while privacy is the primary interest underlying the fourth amendment, Katz v. United States, 389 U.S. 347, 88 S.Ct. 507, 19 L.Ed.2d 576 (1967), that amendment also protects persons against infringements of bodily integrity, Winston v. Lee, 470 U.S. 753, 761, 105 S.Ct. 1611, 1617, 84 L.Ed.2d 662 (1985), and personal dignity, Schmerber v. California, 384 U.S. 757, 767, 86 S.Ct. 1826, 1834, 16 L.Ed.2d 908 (1966). The Court refers to these interests together as "dignitary interests." Winston v. Lee, 470 U.S. at 761, 105 S.Ct. at 1617. It is the privacy and dignitary interests of the female inmates that are violated here.
. Although Turner discusses prison policies that implicate inmates’ first and fourteenth amendment rights, the Turner standard has been applied to prisoners’ fourth amendment rights as well. See, e.g., Covino v. Patrissi, 967 F.2d 73 (2d Cir.1992); Cornwell v. Dahlberg, supra; Michenfelder v. Sumner, supra. The Supreme Court has held that Turner applies whenever "the needs of prison administration implicate constitutional rights." Washington v. Harper, 494 U.S. 210, 224, 110 S.Ct. 1028, 1038, 108 L.Ed.2d 178 (1990). However, the Court has not applied Turner to eighth amendment cases. See Hudson v. McMillian, supra; Wilson v. Seiter, — U.S. —, 111 S.Ct. 2321, 115 L.Ed.2d 271 (1991).
. In addition to Bell, the Court cites as the source of its rule Block v. Rutherford, 468 U.S. 576, 104 S.Ct. 3227, 82 L.Ed.2d 438 (1984); Jones v. North Carolina Prisoners’ Union, 433 U.S. 119, 97 S.Ct. 2532, 53 L.Ed.2d 629 (1977); Pell v. Procunier, 417 U.S. 817, 94 S.Ct. 2800, 41 L.Ed.2d 495 (1974).
. See infra note 11.
. One does not usually speak of "exercising" one’s right to be free from unreasonable searches in the same way that one speaks of exercising one’s right to marry, Turner, 482 U.S. at 94-99, 107 S.Ct. at 2265-67, or one’s right to receive mail, id., 482 U.S. at 91-93, 107 S.Ct. at 2263-64. The "passiv[ity]" of the right involved, Harris v. Thigpen, 941 F.2d 1495, 1517 (11th Cir.1991), has caused this court to observe that the second Turner factor is "much more meaningful in the first amendment context than in the fourth." Michenfelder v. Sumner, 860 F.2d at 331 n. 1. However, while the second Turner factor may ordinarily be of less importance to a fourth amendment inquiry, it is not entirely without significance, and the weight we give it will depend on the circumstances of the case at issue.
. In Turner, the Court found that although some marriage restrictions might be justified by security interests, the prison’s particular anti-marriage prohibitions were not warranted—that they were not reasonably related to a legitimate penological interest. The Court reached this conclusion notwithstanding the Superintendent’s testimony regarding his security concerns and notwithstanding his experience regarding prison security matters. Id.
. The guards’ union stated in its brief that the suspension of the cross-gender policy has forced female guards to incur greater risk because they have more contact with inmates. The record fails to disclose a single injury suffered by a guard as a result of searching an inmate. The union also states that the suspension of the policy has reduced employment opportunities at the prison for male guards, "as entry-level officers must perform such searches.” This speculation is unsupported by the record, which explicitly states that not a single BFOQ has been established because of the injunction. The guards further contend that the injunction discourages women from becoming correctional officers. The record is void of any information that might support such vague speculation. Finally, the guards claim that the suspension of the cross-gender searches "results in a greater risk of contraband being hidden.” This claim was refuted at trial by Superintendent Vail, who, as noted above, testified that the injunction had not prevented prison guards from conducting as many searches as he thought necessary, in locations and at times that he thought necessary, and in a manner of which he approved.
. According to a study conducted by a former clinical psychologist at the prison, eighty-five percent of the inmates have been victims of men’s sexual or other physical violence.
. As noted above, that test is as follows: “The test of reasonableness under the Fourth Amendment ... requires a balancing of the need of the particular search against the invasion of personal rights that the search entails. ” Bell v. Wolfish, 441 U.S. at 559, 99 S.Ct. at 1884 (emphasis added). See supra page 1524.
. The fourth amendment involves an objective test of reasonableness while the eighth amendment requires a subjective inquiry into the state of mind of the prison officials. Graham v. Connor, 490 U.S. 386, 396-400, 109 S.Ct. 1865, 1872-73, 104 L.Ed.2d 443 (1989). It is the subjective inquiry that poses the most difficult problems for both the majority and the dissent. The objective inquiry undertaken here is a far simpler one.
. Under Soldal, if the challenged conduct, analyzed in light of the "explicit textual source of constitutional protection,” leads to the conclusion that a constitutional violation has occurred, the court need go no further. If, however, the court's analysis under the more explicit constitutional provision leads to the conclusion that no violation has occurred, the court must then proceed to examine the conduct in light of the remaining constitutional provision or provisions implicated.
. Although the searches inflict pain, they are not unreasonable simply because of the pain they cause. See supra Part IV.B.(2). The existence of pain is a factor in determining whether the searches are unreasonable, but does not dictate that determination.
. I address the term "search" rather than the term "unreasonable search" because that is the mode of analysis the Court used in Soldal when it addressed "seizure" rather than "unreasonable seizure." Soldal, — U.S. at —-—, 113 S.Ct. at 543-48.
. See, e.g., Harmelin v. Michigan, — U.S. —, 111 S.Ct. 2680, 115 L.Ed.2d 836 (1991) (sentence of life imprisonment without the possibility of parole imposed on a drug offender without prior felony convictions); Penry v. Lynaugh, 492 U.S. 302, 109 S.Ct. 2934, 106 L.Ed.2d 256 (1989) (death penalty applied to mentally disabled man).
. See, e.g., Hudson v. McMillian, supra (prisoner beaten without penological justification); Whitley v. Albers, supra (inmate shot in the knee during a prison riot).
. See, e.g., Estelle v. Gamble, 429 U.S. 97, 97 S.Ct. 285, 50 L.Ed.2d 251 (1976).
. See, e.g., Wilson v. Seiter, supra (mentally and physically ill prisoners housed with healthy prisoners; prison overcrowded and excessively noisy, with inadequate heat, excessive heat, improper ventilation, unclean and inadequate bathrooms, and unsanitary dining facilities and food preparation).
. For examples demonstrating the range of governmental conduct implicated by the due process clause, see Planned Parenthood v. Casey, — U.S. —, 112 S.Ct. 2791, 120 L.Ed.2d 674 (1992) (state abortion statute); Morgan v. Illinois, — U.S. —, 112 S.Ct. 2222, 119 L.Ed.2d 492 (1992) (attributes of jury in capital sentencing); Cruzan v. Director, Missouri Dep’t of Health, 497 U.S. 261, 110 S.Ct. 2841, 111 L.Ed.2d 224 (1990) (right of family members to terminate artificial hydration and nutrition of woman in persistent vegetative state); Michael H. v. Gerald D., 491 U.S. 110, 109 S.Ct. 2333, 105 L.Ed.2d 91 (1989) (parental rights of putative biological father); Bowers v. Hardwick, 478 U.S. 186, 106 S.Ct. 2841, 92 L.Ed.2d 140 (1986) (state sodomy statute); Rochin v. California, 342 U.S. 165, 72 S.Ct. 205, 96 L.Ed. 183 (1952) (propriety of pumping suspect’s stomach to retrieve capsules of narcotics).
. We have once before considered the constitutionality of a prison’s policy of cross-gender searches. In Grummett v. Rushen, 779 F.2d 491 (9th Cir.1985), we found "routine pat-down searches, which include the groin area," conducted by female guards on male inmates, to be constitutional. Id. at 495, 496. Holding the cross-gender searches at issue here unconstitutional is not inconsistent with Grummett; the type of injury caused by the current searches is quite different from that which we considered there. See supra Part IV.B.(2).
. See supra note 16.
. A search does not violate the fourth amendment if it is reasonable. A search of prisoners’ bodies that inflicts pain yet is reasonable cannot, by definition, constitute cruel and unusual punishment, because only conduct that wantonly inflicts unnecessary pain constitutes such punishment. Wilson v. Seiter, — U.S. at —, 111 S.Ct. at 2324. Pain cannot be deemed wantonly and unnecessarily inflicted if the search that inflicted it is judged to be necessary — or reasonable.