Maryland Penitentiary v. Hayden Warden - Impact

The decision in Hayden adopted privacy as the measure of an individual's interest protected by the Fourth Amendment. This proposition was solidified mere months later, when the Court in Katz v. United States (1967) again based its analysis of a questionable police search on privacy principles rather than property principles. The effect of this shift has not led to more predictability in Fourth Amendment analyses, but it has fostered analyses that the Court believes comports with the basic intent of the Fourth Amendment--the protection against unreasonable searches and seizures.