Until recently, Federal courts avoided prisoners' rights issues by claiming that correctional practices were beyond their jurisdiction and expertise. These justifications have been discredited by the Supreme Court, and the constitutional review of treatment of prisoners has thus increased. A fundamental split, however, exists in the circuit courts' opinions regarding the rights of pretrial detainees. The courts in Hampton v. Homesburg Prison Officials and Feely v. Sampson reasoned that detainees' status as innocent persons did not entitle them to more favorable treatment that convicted prisoners and that the burden of proving unreasonable restrictions based on institutional security and to guarantee the detainee's presence at trial. In Bell v. Wolfish, the Supreme Court reversed a lower court's decision that inmates of the Metropolitan Correctional Center could not be subjected to traditional prison restrictions, such as banning receipt of hardback books unless sent from a publisher, conducting body cavity searches without probable cause, and banning all packages except at Christmas. The Court ruled that the presumption of innocence was irrelevant and that Federal courts should not interfere in the daily management of detention centers. Dissenting opinions criticized the majority's reliance on Kennedy v. Mendoza - Martinez and its narrow definition of punishment. The court ignored fundamental distinctions between prisoners and detainees and shirked its responsibility to protect detainees from the arbitrary practices of detention officials. The Wolfish precedent has already influenced other judicial decisions which supported the authority of detention centers to ban visits between detainees and outside visitors and to refuse methadone treatment. The Wolfish ruling is too superficial to deal effectively with the complex issues resulting from pretrial confinement because it precludes judges from considering the impact of restrictions on the liberty of detainees. Over 60 footnotes are included.