dissenting.
In holding that Officer Watson’s war-rantless strip-search of a seventeen-year-old girl was “reasonable” under the Fourth Amendment, the district court relied on the “special needs” exception to the rule that all warrantless searches are presumptively unreasonable. In affirming that dubious holding, the majority untethers the *368district court’s language from its reasoning, and in a single paragraph of analysis, relies on United States v. Knights, 534 U.S. 112, 121, 122 S.Ct. 587, 151 L.Ed.2d 497 (2001), to conclude that “reasonable suspicion” is all that is necessary to justify a strip-search of a juvenile in a private group home by police acting without authorization from that home’s staff. I believe the district court was wrong to conclude that this was a valid “special needs” search, I believe the majority is wrong to rely on Knights rather than the general rule that a warrantless search is presumptively unreasonable unless falling into an enumerated exception, and I believe that even under the balancing test used in Knights, this search was unreasonable.
The majority relies upon the district court’s recitation of facts, and in doing'so amplifies the district court’s errors. The “basic underlying facts” are not “undisputed”; a thorough review of the record reveals that the version of events given by the police officers in their deposition testimony and written reports and that of the staff of the Bellewood home and its residents are wildly divergent. Compare Dep. of Officer Watson, R. 119, at 32 (“I tried to do it [the strip-searches] as gently as possible and considerate as possible”) with Dep. of Katherine Reynolds, R. 92, at 157 (“And then [Watson] said,” “If you don’t take off the f* * *ing bra, I’m going to take it off for you.”) and Dep. of Sarah Lynette Holman, R. 101, at 44-45 (describing Watson as “rude” and “cocky”). This divergence is most acute at what I believe to be a key juncture: whether or not the strip-searches of the residents of Haney Cottage were authorized by staff members or instead were initiated by police. It is of course the facts as asserted by Katherine Reynolds (“Reynolds”), the non-moving party, that we must follow. Bellewood Presbyterian Home for Children (“Belle-wood”) is a private group home for abused and at-risk children, with an explicitly religious mission, which is under contract to the Kentucky Cabinet for Human Resources. Reynolds was sent to Bellewood after being adjudicated delinquent for marijuana possession, second-degree forgery, and fraudulent use of a credit card. Joint Appendix (“J.A.”) at 84. While Reynolds and others were sent to Belle-wood after juvenile delinquency proceedings, this is not true of all of Bellewood’s residents. Reynolds was seventeen at the time of the incident, and lived at Haney Cottage with other juveniles and staff members. J.A. at 207, 213, 218.
On June 8, 1997, Reynolds and two other residents of Haney Cottage took a walk on the Bellewood grounds. When they returned, they were acting “strange” and two Bellewood staff members, Melissa Adamchik (“Adamchik”)1 and Stephanie Jacob (“Jacob”), suspected the girls of using drugs. J.A. at 89. At roughly the same time, Anchorage Police Officer Toby Lewis (“Lewis”), whose beat included Bellewood, called the cottage from his cell phone as he drove by. Lewis testified that he called “just to say hi.” J.A. at 157. During the course of the friendly conversation, Adamchik and Jacob informed Lewis of their suspicions of drug use. J.A. at 86, 143-44, 158-62. Lewis then entered the cottage, and the decision was made to search the girls’ rooms. J.A. at 158-62. Lewis’s deposition testimony was that Adamchik and Jacob had asked him to search the girls, and when he informed them that he could not, and offered to search the rooms, they then asked him to do that. J.A. at 161-63. Adamchik testified that they did not ask Lewis to per*369form a search, which conforms to her account of events in written incident reports, but that a call was placed to Carol Woch-enko, head therapist for Haney Cottage, who indicated her approval of the room searches. J.A. at 80, 89, 121-22; Dep. of Melissa Adamchik, R. 162, at 37. Lewis called in for backup, and Officer James Ennis (“Ennis”) arrived at the scene. A search of all five rooms at Haney Cottage ensued, during which time a third Anchorage police officer, Officer Timothy Young (<cYoung”) arrived. J.A. at 86. In Reynolds’s room, two packs of cigarettes and an empty plastic bag (the “plastic baggy ... which the officers believe may have contained drugs” noted by the majority) were found; in other residents’ rooms, seven lawfully-prescribed Depakote tablets, a clear vial with a white powder residue, and a small baggie with trace amounts of an unidentified brown substance were found. J.A. at 86. The latter two items were later sent to be tested, and the powder turned out to be non-drug related, while the brown substance was not substantial enough to be tested. J.A. at 186. The district court stated that Reynolds and other Haney Cottage residents “admitted having previously used drugs while living” at the cottage, J.A. at 29. Presumably this is meant to have relevance in determining the reasonableness of subsequent events; this statement may refer to Officer Lewis’s testimony that at a prior talk he had given to the residents of Haney Cottage, Reynolds had stated “that she has used drugs in the past and she will continue to use drugs.” Dep. of Toby Lewis at 93-94. Whatever the reliability of this hearsay, such adolescent bravado has limited value in determining whether Reynolds had contraband on her person at some future time.
At this point, the majority repeats the district court’s description of a statement by Reynolds to the supposed effect “that she might have drugs hidden in her undergarments.” In fact, frustrated by what she no doubt saw as an intrusive and ultimately fruitless search of her residence, Reynolds pointed out to Jacob that room searches were useless, because the girls could have contraband on their persons. “[I]t just seemed kind of pointless to me.” J.A. at 261 (Dep. of Katherine Reynolds). The decision was then made to perform a strip-search on the girls. According to Lewis, it was Ennis who made the instant decision to search the girls, but consistent with his earlier testimony that the entire incident was prompted by a staff request to search the girls, Lewis also testified that when Watson arrived, he informed Watson that the staff had requested that the girls be searched. J.A. at 189-90,199-200. Watson testified that when she arrived, both staff members and her three fellow officers individually requested that she perform the search. J.A. at 274-75, Dep. of Leslie Watson at 15-19. Adam-chik, on the other hand, testified that the first mention of strip-searches came from the officers, that she did not request the strip-searches, and that she never heard Jacob request the strip-searches. J.A. at 128-29, 134-35, 137-38. No further phone call was placed to Carol Wochenko. Reynolds testified that Adamchik or Jacob informed her that the police had decided to strip-search the girls, and other Haney Cottage residents described Adamchik as visibly physically distressed at the strip-searches. Dep. of Katherine Reynolds at 143-44, 180 (“[S]he said that they [the police] were the ones that initiated it, the strip search”); Dep. of Carla Dana Hudson at 184-85; Dep. of Shatonya Lanyce Elam at 136-37. At that point, each girl was taken into her own room by Watson and strip-searched with Adamchik present. Although Watson testified that each girl was first instructed to remove her shirt *370and bra, and then put them back on, and then remove her pants and underwear and bend over, and then put her clothing back on, at least one of the girls testified that to the contrary, she was entirely naked during the search. J.A. at 283-84 (Dep. of Leslie Watson); Dep. of Sarah Lynette Holman, R. 101, at 45. Each girl was also made to bend over and spread her buttocks. No drugs were discovered.
“Warrantless searches are per se unreasonable under the fourth amendment, except in a few carefully delineated instances.” United States v. Radka, 904 F.2d 357, 360 (6th Cir.1990); see also Groh v. Ramirez, 540 U.S. 551, — , 124 S.Ct. 1284, 1290-91, 157 L.Ed.2d 1068 (2004) (reaffirming presumption that war-rantless searches are unreasonable in context of search of home). Those exceptions include automobile searches, consented-to searches, searches incident to arrest, seizures of items in plain view, Terry stops, the hot-pursuit rule, and searches in order to prevent the loss or destruction of evidence. The district court relied upon the “special needs” doctrine in granting qualified immunity to Watson. J.A. at 29, 34-35. The “special needs” doctrine, first articulated by Justice Blackmun in his concurring opinion in New Jersey v. T.L.O., 469 U.S. 325, 351, 105 S.Ct. 733, 83 L.Ed.2d 720 (1985), constitutes an exception to the rule that all searches must be pursuant to a search warrant obtained by the demonstration of probable cause in those cases where “special needs, beyond the normal need for law enforcement, make the warrant and probable-cause requirement impracticable.” Id. T.L.O. involved a search of a public-school student by school officials on the basis of particularized suspicion, but the “special needs” doctrine has since been extended by the Supreme Court to allow suspicionless drug testing of public-school students involved in after-school activities, see Bd. of Educ. of Indep. Sch. Dist. No. 92 v. Earls, 536 U.S. 822, 122 S.Ct. 2559, 153 L.Ed.2d 735 (1990), and workers in sensitive industries, see Skinner v. Ry. Labor Executives’ Ass’n, 489 U.S. 602, 109 S.Ct. 1402, 103 L.Ed.2d 639 (1989) (railway employees who violate safety rules or who are involved in accidents); Nat’l Treasury Employees Union v. Von Raab, 489 U.S. 656, 109 S.Ct. 1384, 103 L.Ed.2d 685 (1989) (customs officials who carry a firearm or work in drug interdiction), sobriety checkpoints, see Mich. Dep’t of State Police v. Sitz, 496 U.S. 444, 110 S.Ct. 2481, 110 L.Ed.2d 412 (1990), and warrantless searches of probationers’ private residences, see Griffin v. Wisconsin, 483 U.S. 868, 107 S.Ct. 3164, 97 L.Ed.2d 709 (1987). The Court has made clear, however, that searches whose primary purpose is law enforcement are not “special needs” searches. See Ferguson v. City of Charleston, 532 U.S. 67, 121 S.Ct. 1281, 149 L.Ed.2d 205 (2001); City of Indianapolis v. Edmond, 531 U.S. 32, 121 S.Ct. 447, 148 L.Ed.2d 333 (2000). Although Bell v. Wolfish, 441 U.S. 520, 99 S.Ct. 1861, 60 L.Ed.2d 447 (1979), predates T.L.O., its holding that pretrial detainees can be subject to body-cavity searches after every contact visit consonant with the Fourth Amendment has been later contextualized by the Supreme Court as part of the “special needs” doctrine. See Skinner, 489 U.S. at 619-20, 109 S.Ct. 1402. Each case cited by the majority in the first part of its analysis is thus part of the “special needs” exception to the warrantless search per se rule.
Under the “special needs” doctrine, a search of a particular student, with the exception of drug testing, must be supported by reasonable suspicion, which Reynolds concedes exists in this case. Reynolds’s Reply Brief at 1; T.L.O., 469 U.S. at 341-42, 105 S.Ct. 733. We have *371relied upon this holding to extend qualified immunity to officials performing strip-searches of public-school students for drugs. See Williams v. Ellington, 936 F.2d 881, 887-89 (6th Cir.1991). The majority therefore is likely correct to conclude that Bellewood Home “had a strong interest in eliminating and preventing drug use on the premises by its residents” that could support a warrantless strip-search of Reynolds by Bellewood’s staff upon reasonable suspicion that she was concealing contraband on her person. The majority in the next paragraph then reveals its logical misstep in stating, “The police officers justifiably concluded that the only way to assuage these concerns ... was to strip-search the girls.” This marriage between the needs of the Bellewood Home and the conclusions and actions of the police officers is not merely a question of the identity of the searcher, but of the object of the search. Whether a warrantless strip-search initiated and authorized by Belle-wood staff, but conducted by police, would have been a valid “special needs” search was a question expressly left open by T.L.O., 469 U.S. at 342 n. 7, 105 S.Ct. 733 (reserving question of “searches conducted by school officials in conjunction with or at the behest of law enforcement agencies”). This question is thus perhaps deserving of more than a page of analysis in its answer, but that answer is entirely academic in this case: taking Reynolds’s version of facts as correct, we must assume that police initiated and performed the strip-searches on their own. Under those facts, it becomes clear that a constitutional violation did, in fact, occur. Police officers, invited onto private property, cannot initiate a warrant-less strip-search of citizens merely because some other authority has the right to search those citizens to maintain order in its facility. That result is clearly contrary to the sharp line drawn by the Supreme Court between valid “special needs” searches and those that are unlawful because they serve ordinary law enforcement goals as well as special needs. See Ferguson, 532 U.S. at 79-80, 121 S.Ct. 1281.
The majority in its ultimate conclusion that no constitutional violation occurred relies on United States v. Knights, 534 U.S. 112, 122 S.Ct. 587, 151 L.Ed.2d 497 (2001). To the extent that Knights eschewed reliance on the “special needs” exception to the general rule that a warrant-less search is unconstitutional in favor of a more general balancing approach, that case is necessarily limited to its facts by subsequent cases which have reaffirmed the per se rule/carefully delineated exceptions approach to warrantless searches of the home. See Groh, 540 U.S. at -, 124 S.Ct. at 1290-91. In fact, Knights has not been cited again by the Supreme Court in deciding nearly a dozen cases involving Fourth Amendment reasonableness. Nonetheless, even assessing the search under Knights’s general reasonableness equation, I believe this search was still unreasonable, because the key problem with this search is that the government had no interest in it beyond a generalized interest in law enforcement, and that interest cannot justify the strip-search, particularly of a minor, based merely on reasonable suspicion. See Knights, 534 U.S. at 118-19, 122 S.Ct. 587 (“reasonableness of a search is determined ‘by assessing, on the one hand, the degree to which it intrudes upon an individual’s privacy and, on the other, the degree to which it is needed for the promotion of legitimate governmental interests.’ ”) (quoting Wyoming v. Houghton, 526 U.S. 295, 300, 119 S.Ct. 1297, 143 L.Ed.2d 408 (1999)). While Bellewood had an interest in maintaining order in its facility, one that may have been served by the search of Reynolds, Bellewood was not the entity searching Reynolds, nor is it necessarily a *372governmental entity at all; it is a private religious home for children. Whether or not that private institution can “deputize” police officers to search its residents, surely police officers cannot of their own initiative do so without being subject to the normal rules governing such searches. If Reynolds had been home on a weekend visit, as was regular, and her parents had invited Watson into the home to speak to Reynolds about the dangers of drug use, would the majority hold that Watson could then proceed to strip-search Reynolds without her parents’ permission because their interests in keeping their daughter away from drugs justified the intrusion on Reynolds’s right to be free from unreasonable searches? I see little logical distinction between such obviously excessive police behavior and the actions of police we must assume took place here.
Finally, I disagree that Watson is entitled to qualified immunity. Because the general rule that a warrantless search is unreasonable was clearly established in 1997, I believe that the majority inverts the proper inquiry when it notes that no court has addressed the application of the Fourth Amendment to the situation before us today in support of qualified immunity; instead, if no case suggests that a police officer is entitled to rely on similar administrative “special needs” in initiating a strip-search herself, Watson is not immune from suit. No cases in our circuit, nor indeed any court addressing the related issue of when searches on school grounds are appropriate, suggest that Watson’s actions were justified.2
Since T.L.O., courts have generally held that T.L.O.’s reasonable-suspicion standard applies to searches conducted by law enforcement officials at the behest of school officials. See Shade v. City of Farmington, 309 F.3d 1054, 1060 (8th Cir.2002) (search constitutional where “school officials, not law enforcement officers, initiated the investigation and the search”); Cason v. Cook, 810 F.2d 188, 192 (8th Cir.1987) (no violation where “no indication that but for the deputy’s involvement, the plaintiff would not have been searched”); State v. N.G.B., 806 So.2d 567, 568-69 (Fl.Dist.Ct.App.2002) (“reasonable suspicion was the appropriate standard” where search of student by police officer was initiated and directed by school official); In re Josue T., 128 N.M. 56, 989 P.2d 431, 437 (1999) (reasonable suspicion applies where police officer “merely assisted the school official, during the school day, at the school official’s request, to protect student welfare and the educational milieu”); In re Angelia D.B., 211 Wis.2d 140, 564 N.W.2d 682, 688, 690 (1997) (reasonable suspicion standard applies where school liaison officer “became involved in th[e] investigation only after school officials requested his assistance” and worked in conjunction with school officials). But see In re A.J.M., 617 So.2d 1137, 1138 (Fl.Dist.Ct.App.1993) (where police officer “directed, participated in or acquiesced in the search,” probable cause is required). Other courts have also held that where a police officer is employed by the school or school district and the search is consonant with the “special needs” of school discipline, the T.L.O. standard also applies. See People v. Dilworth, 169 Ill.2d 195, 214 Ill.Dec. 456, 661 N.E.2d 310, 317 (1996). But when confronted with a search like that at issue here, initiated by law enforcement officers not under the supervisory control of school authorities, courts have uniformly held *373that probable cause is required. See In re F.P., 528 So.2d 1253, 1254 (Fl.Dist.Ct.App.1988) (exception to probable cause requirement “does not apply when the search is carried out at the behest of the police”); State v. Tywayne H., 123 N.M. 42, 933 P.2d 251, 254 (1997) (T.L.O. standard inapplicable where search “conducted completely at the discretion of the police officers”); In re Thomas B.D., 326 S.C. 614, 486 S.E.2d 498, 500, 504-506 (1997) (while search was of student and took place on school property, T.L.O. standard inapplicable because police were acting on their own authority and not as agents of the school). See generally Wayne R. LaFave, Search and Seizure § 10.11 (discussing three categories of cases). These cases demonstrate once again that the “special needs” doctrine is wholly inapplicable on Reynolds’s version of the facts, where police, unconnected to the institution whose “special needs” are said to justify the search, conducted searches on their own initiative. See also Tatter v. Raybuck, 742 F.2d 977, 983 (6th Cir.1984) (pre-T.L.O. case noting that “[t]he presence of the police officers does take this case purely out of the context of school officials seeking to maintain an environment conducive to the educational process” but concluding that “involvement of the police with respect to the plaintiff is marginal” in case where plaintiff was searched only by school officials acting on their own). The consensus of all prior courts is that when police act on their own initiative, they cannot rely on the “special needs” of school officials. See F.P., 528 So.2d at 1254; Tywayne H., 933 P.2d at 254; Thomas B.D., 486 S.E.2d at 500, 504-506.
I would therefore reverse the district court’s decision and remand the case for trial.
. Melissa Adamchik is the staff member's married name; in the record, she is sometimes identified by her maiden name, Melissa Wambaugh.
. United States v. Knights, 534 U.S. 112, 121, 122 S.Ct. 587, 151 L.Ed.2d 497 (2001), can of course offer Watson no help at this stage of the inquiry, as it was decided after the events in question took place; additionally, there is no indication anywhere in the record that Watson knew that Reynolds was herself a delinquent or that Haney Cottage was home only to delinquents.