1. Facts (summarize the background facts of the case)
1.1. Parties
1.1.1. City of Los Angeles
1.1.2. The Patels: A group of motel operators along with a lodging association
1.2. What Happened
1.2.1. The Los Angeles Municipal Code (LAMC) §41.49 requires hotel operators to record information about their guests, and specifically in Section 41.49(3)(a), the hotel records must be made available to LAPD for inspection and refusal to comply will be considered a misdemeanor punishable by up to six months in jail and a $1,000 fine.
1.2.2. The city of Los Angeles tried to convince the court that LAMC 41.49(3)(a) should stand and that facial challenges to the Fourth Amendment should not be allowed
1.2.3. "Naranjibhai and Ramilaben Patel, two Los Angeles hotel owners, challenged the law as authorizing a regime of unconstitutional searches." Stanwood, S. (2015, June 22). Supreme Court Strikes Down Warrantless Searches of Hotel Records, Reaffirms Fourth Amendment Facial Challenges. Electronic Frontier Foundation. Supreme Court Strikes Down Warrantless Searches of Hotel Records, Reaffirms Fourth Amendment Facial Challenges
1.3. Procedural History
1.3.1. First there was a bench trial and the District Court's judgement was in favor of the City.
1.3.2. A divided Ninth Circuit panel also affirmed judgement in favor of the City.
1.3.3. After a rehearing en banc, the Court of Appeals reversed the initial decision.
1.3.3.1. The court held that the LAMC 41.49(3)(a) was facially unconstitutional as it authorized inspections without allowing the hotels the opportunity to "obtain judicial review of the reasonableness of the demand prior to suffering penalties for refusing to comply".
1.3.4. The case was brought up to the Supreme Court
2. Issue (identify the legal question before the court)
2.1. §41.49(3)(a) states that the hotel guest records would be allowed to be reviewed by the LAPD without a warrant.
2.1.1. The Respondents have been subjected to mandatory record inspections by the LAPD without consent, a warrant, or the ability for judicial review.
2.2. Under the Fourth Amendment, most searches will require a warrant. If if law in question allows for a search without a warrant, it would be considered unconstitutional unless it falls under a select few exceptions.
2.2.1. The exceptions are for "highly regulated" businesses (such as alcohol distribution or gun sellers), where the Supreme Court has previously founded that those should have no expectation of privacy and will have less protection under the Fourth Amendment.
3. Rule of Law (identify and describe the legal principles and legal precedent the court will use to answer the Issue)
3.1. The Fourth Amendment protects the “right of the people to be secure in their persons, houses, papers, and effects.” Before searching or seizing private property, law enforcement officers must usually obtain a search warrant—an order from a judge or other public official authorizing the search or seizure...To obtain a search warrant, law enforcement officers must convince a judge that they have reasonable grounds, or probable cause, to believe a search will reveal evidence of a specific illegality. To establish probable cause, the officers must have trustworthy evidence that would convince a reasonable person that the proposed search or seizure is more likely justified than not. Cross, Frank B.; Miller, Roger LeRoy. The Legal Environment of Business: Text and Cases (MindTap Course List) (p. 38). Cengage Learning. Kindle Edition.
3.2. There are a few specific examples of exceptions: "This rule “applies to commercial premises as well as to homes.” Marshall v. Barlow’s, Inc., 436 U. S. 307, 312 (1978). Search regimes where no warrant is ever required may be reasonable where “‘special needs . . . make the warrant and probable-cause requirement impracticable,’” Skinner, 489 U. S., at 619 (quoting Griffin v. Wisconsin, 483 U. S. 868, 873 (1987) (some internal quotation marks omitted)), and where the “primary purpose” of the searches is “[d]istinguishable from the general interest in crime control,” Indianapolis v. Edmond, 531 U. S. 32, 44 (2000)."" (Los Angeles v. Patel, 2015).
4. Analysis and Application (analyze how the Rule would be applied in this case)
4.1. Plaintiff (How did the Plaintiff interpret, present, and argue the Rule?)
4.1.1. The Plaintiff defended their statute, asserting that facial challenges to statues allowing for searches without warrants will always fail. It could never be unconstitutional in application, especially in certain cases.
4.1.2. An example the City presented: Situations where police are responding to emergencies and acting under a court-ordered warrant. The subject in the emergency consents to the search and intrusion.
4.2. Defendant (How did the Defendant interpret, present, and argue the Rule?)
4.2.1. The Defendant asserts that the LAMC 41.49(3)(a) statute was unconstitutional. The Defendants were subjected to mandatory inspections by the City without any consent or warrant.
4.2.2. Hotels did not fall into the "highly regulated" industries that were the exception to the Rule.
4.2.3. The Defendants were also not given a chance to pre-compliance review by a neutral party before records were demanded. If they did not comply, they could be arrested on the spot and subjected to a misdemeanor charge with penalties of jail time and fines.
4.3. Court (How did the Court apply the Rule in making its decision Also, consider: Did the court expand, reinterpret, or narrow the law to reach its conclusion?; What facts were compelling to the court in its analysis?; Did it use analogy or make any public policy arguments?)
4.3.1. It is assumed that the searches authorized under §41.49 were not for criminal investigations. It was to ensure hotels were keeping up their records, which prevents criminals from operating their business on hotel grounds. The Court referred to these searches as "administrative searches" and could be an exception to the requirement of having a warrant. In order for these administrative searches to be constitutional, the subject must be allowed a pre-compliance review before a neutral decision-maker. §41.49(3)(a) does not give the hotel operators the opportunity for pre-compliance review, which therefore makes it unconstitutional.
4.3.2. The Plaintiff's example of situations when police are responding to emergencies is in opposition to the exceptions of the Fourth Amendment allowing for searches without warrants, specifically when the subject consents to search. The Court thus presents evidence that certain facial challenges to warrantless search statutes could be legal.
4.3.3. The Court stated that the hotel owners could not be arrested on the spot or charged with penalties, especially if they were not given the chance for pre-compliance review before the records were searches. This review is only needed if the hotel owner objects to turning over their records, and not so if they consent.
5. Conclusion (describe the decision of the court, and whether and how the Rule applies)
5.1. The Supreme Court agreed with the Ninth Circuit and ruled that §41.49(3)(a) was facially unconstitutional as it infringed on the hotel owner's rights when it penalizes them for refusing to give up their records without an opportunity for pre-compliance review.
5.2. Facial challenges to statues under the Fourth Amendment are "not categorically barred or especially disfavored" (Los Angeles v. Patel, 2015), which means that individuals can continue to challenge and bring to court laws that infringe upon their constitutional rights.
6. Impact (identify and describe at least two cases that have cited the holding)
6.1. Brown v. City of Atlanta, 2018
6.1.1. Defendants originally had search and arrest warrants for a business suspected of criminal behavior, but during the time of inspection, the business was closed. They decided to pursue other suspicious businesses on the grounds that they had already obtained warrants. Brown was the president of the establishment the officers entered and searched.
6.1.2. Los Angeles v. Patel was cited during their discussion on administrative searches and the exceptions to the law requiring warrants such as the highly regulated busnesses.
6.2. Weisenberg v. Town Bd. of Shelter Island, 2019
6.2.1. Shelter Island enacted the "Short-Term-Rental Law" which "...imposes licensing and advertising requirements for certain vacation rentals, prohibits regulated vacation rentals from being rented more than once in any fourteen-day period, provides civil penalties for violations, and empowers the Town Board to act as the review board for issues associated with the implementation of the Law" (Weisenberg v. Town Bd. of Shelter Island, 2019).
6.2.2. Since enactment of the Law, multiple Plaintiffs have claimed loss of income because they could not rent out to customers for under fourteen days.
6.2.3. Los Angeles v. Patel was cited on discussion of administrative searches and how they had to give the option of compliance review in order to be constitutional.