City Los Angeles V Patel

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City Los Angeles V Patel by Mind Map: City Los Angeles V Patel

1. Facts

1.1. Parties

1.1.1. Ramilaben Patel and Naranjibhai owners and operators of motels in Los Angeles city.

1.1.2. The City of Los Angeles

1.2. What happened?

1.2.1. The Los Angeles Municipal Code requires motel operators to maintain registers containing relevant customer information such as: license plate numbers, state issued ids/drivers licenses, phone numbers, credit card information, and name and address. The LAMC also required the motels to have at least 90 days worth of history in the register, to be made available to police officers. However, Patel argued that the provision is in violation of the 4th amendment, unreasonable search and seizure. The city stated that the motel/hotel industry is closely regulated and therefore do not require warrants for inspections.

1.3. Procedural History

1.3.1. District Court Case was first reviewed by the District Court which ruled that the motels were not the same as other businesses and therefore did not qualify as closely regulated businesses. However the court also ruled that motels did not have ownership interested that brings about the privacy rights in their records, as they were solely created to comply with the ordinance. U.S. Court of Appeals for the Ninth Circuit At first the court affirmed, but the reverted to rehearing en band. The Appellate court stated that the records were considered to be "private records" protected under the Fourth Amendment, making LAMC's warrantless inspections to be unreasonable as it did not provide pre-compliance judicial review of an officer's request to search the records.

1.3.2. U.S. Supreme Court The court concluded in a 5-4 ruling, that hotels and motels are closely regulated businesses. Therefore, 41.49 LAMC is not violation of the Fourth Amendment, thereby making unwarranted inspections permissible.

2. Issue

2.1. The LAMC requires hotel and motel owners/operators to collect guest information with a history of at least 90 days. This register must be made available and accessible in public areas, such as the front desk. Additionally, the register must be made available to any police officer within the Los Angeles Police Department upon request for inspection. Failure to comply will result in a misdemeanor punishable to up to six months in jail and a $1,000 fine.

3. Rule of Law

3.1. Fourth Amendment the right to protection against unwarranted search and seizure.

3.2. Los Angeles Municipal Code 41.49 requires hotels and motels, "closely regulated" businesses, to comply with unwarranted inspections of registries upon demand by police officers.

4. Analysis

4.1. Plaintiff

4.1.1. Interpretation Patel interpreted the law that it was a violation under the Fourth Amendment, protection against unwarranted search and seizure.

4.1.2. Presentation The Plaintiff facially challenged the Los Angeles Municipal Code 41.49 requirement to present the register information to any officers upon demand of inspection, was against the Fourth Amendment the right to unwarranted search and seizure.

4.1.3. Argument Patel argued specifically that leaving the register in a public area to be accessible to officers at anytime was unconstitutional under the Fourth Amendment.

4.2. Defendant

4.2.1. Interpretation The City of Los Angeles interpreted the rule of law is not facially challengeable and is not unconstitutional.

4.2.2. Presentation The city presented the case that it is not facially challenging, hotels and motels have no "expectation of privacy" since the guest registers are often kept in the check in desk, a publicly accessible area. There is no right to privacy in public areas.

4.2.3. Argument The defendant argued that the hotels and motels in LA are closely regulated, and therefore are subject as permissible to unwarranted inspections.

4.3. Court

4.3.1. The court rule applied in making it's decision by using examples of how the 41.49 LAMC is permissible, making the businesses subject to warrantless inspections.

4.3.2. The facts that were compelling to the court in its analysis, the location of the register - how it's located in a public area, reasons as to why motels specifically should be closely regulated or are closely regulated, examples of sex trafficking, human trafficking, and drug dealings and doing drugs often take place in a motel. The other facts also included the anonymity that motels provide to harboring criminals, supporting the reasons why warrantless searches are not against the Fourth Amendment.The court also provided five examples of scenarios where the unwarranted searches/inspections are allowed. These examples were used as supporting evidence and facts in declaring the court's final ruling.

5. Conclusion

5.1. The final decision of the court was 5-4 in which it was determined that the 41.49 regulations was not unconstitutional. The court stated that motels and hotels are closely regulated and therefore unwarranted inspections were allowed, with in line the required regulations.

6. Impact

6.1. Florida v Jardines in Miami-Dade Police received a tip that there was marijuana growing/use at the home of Joelis Jardines. A drug dog was used to positively identify the scent of marijuana drug. Plaintiff argued that the drug dog's sniff was an unwarranted search under the Fourth Amendment and all evidence was proof of the poisonous fruit. The case questioned whether or not the use of drug dogs sniffing was considered an unwarranted search in violation of the Fourth Amendment protection against search and seizure.

6.2. Nelson Sibron was arrested for drug trafficking, in which he attempted to prevent the heroin as evidence bu arguing there was an unconstitutional stop and frisk search. The case questioned whether or not the NY State Police violated the Fourth Amendment through use of the protocol "stop and frisk" law.

7. Importance

7.1. A business professional would care about this decision as it allows for customer information and PII to be accessible to the L.A. Police upon demand. It also causes privacy issues, which could contribute to possible loss of business. For example, if a customer does not feel comfortable having their personal information recorded and is made accessible in a public area, they may decide not to stay at the establishment.

8. Influence

8.1. The two business practices that have been influenced and impacted by the final ruling are guest privacy and accountability in the protection and privacy of their guests' information.

9. Citations

9.1. The City of Los Angeles v Patel, et. al (June 23, 2015).

9.2. III, C. (2015, November 10). City of Los Angeles v. Patel. Retrieved November 09, 2020, from City of Los Angeles v. Patel

9.3. City of Los Angeles v. Patel. (n.d.). Retrieved November 09, 2020, from

9.4. Sibron v. New York. (n.d.). Retrieved November 09, 2020, from

9.5. Florida v. Jardines. (n.d.). Retrieved November 09, 2020, from