In presenting Eighth Amendment claims pertinent to the conditions of confinement, plaintiffs must show that the defendant not only injured the plaintiff but did so in a manner that evinces a culpable state of mind. Culpability is measured under one of two applicable standards: "deliberate indifference," which applies when inmates allege harmful conditions of confinement, or malicious intent, when use of force is challenged as excessive. This article argues that the Jordan court erred in holding that the policy of random, cross-gender searches constituted cruel and unusual punishment. By applying the deliberate-indifference standard to find a prison security measure unconstitutional, the court extended the standard beyond the use intended by the U.S. Supreme Court. Further, this expansion will erode the predictive value of Eighth Amendment jurisprudence and allow judges to substitute imprudently their own values for the experience and expertise of prison officials. 130 footnotes