City of Los Angeles v Patel, 576 U.S. 409 (2015)

1. Analysis

1.1. Plaintiff: The motel operators suggested that they have been subjected to mandatory record inspections under LAMC ordinance without consent or a warrant.

1.2. Defendant: The City of Los Angeles argues that the motel operators do not have a reasonable expectation of privacy, and that facial challenges to the 4th amendment must fail as they can never by universally constitutional under all circumstances.

1.3. Courts

1.3.1. District Court: The district court initially agreed with the defendant in that there was no reasonable expectation of privacy, and that the records the motel owners created were in order to comply with the ordinance in the first place.

1.3.2. Court of Appeals: The court of appeals reversed the District Court's ruling, stating that the hotel records were the private property of the motel operators, and therefore the "search" was covered under the 4th amendment.

1.3.3. Supreme Court: The Supreme Court declares that 4th amendment facial challenges are not barred or disfavored. Furthermore, the Supreme Court declares that the city ordinance is unconstitutional, as it prevents the motel operators an opportunity to demonstrate pre-compliance and can be conducted without a judicial review.

1.3.3.1. Precedent 1: Katz v. United States, 389 U. S. 347, 357 (1967), which states that a warrant is necessary for businesses, as well as private homes.

1.3.3.2. Precedent 2: Griffin v. Wisconsin, 483 U. S. 868, 873 (1987), which states that in order to execute a search without a warrant requires "special circumstances," such as imminent crime control.

1.3.3.3. The Supreme Court noted that only four industries have been subject to searches without warrant: Firearms, Mining, Alcohol, and Automotive junkyard. These industries were chosen as they can present harm to society. The Supreme Court determined that there is nothing about the motel industry that inherently puts society at risk, and these closely regulated industries are the exception.

2. Conclusion

2.1. Importance: This case is important as it clearly draws a line, as it pertains to business, between different industries, and how the 4th amendment applies to them. For highly regulated industries, such as the sale of firearms, there are exceptions to the 4th amendment in the favor of a greater public good. However, in less regulated industries, the rights afforded by the 4th amendment are favored, as those industries pose little risk to public harm.

2.2. Influences:

2.2.1. The implications of this ruling show that businesses hold many of the same protections granted by the 4th amendment as individuals do. However, it would be prudent for businesses to develop a business process to demonstrate pre-compliance.

3. Facts

3.1. Plaintiff: Motel Operators (Patel)

3.2. What happened: A group of motel operators kept papers on guests who used their motel service. The Los Angeles Police Department, under city ordinance, would conduct inspections of these papers without a warrant, per established city ordinance.

3.3. Procedural History: The issue was first heard at the district court. Following it's decision, the court of appeals heard, and reversed, the decision. An en blanc court was held, ultimately rising to the Supreme Court.

3.4. Defendant: City of Los Angeles

4. Issue

4.1. The issue is whether Los Angeles Municipal Code Secion 41.49(3) is a violation of motel owner's 4th Amendment Constitutional rights.

5. Rule

5.1. Constitution: 4th Amendment, which affords the right to be secure against unlawful search and seizure.

5.2. Los Angeles Municipal Code (LAMC) Section 41.49(3)(a) states that hotel goest records must be made available to Los Angeles Police Officers for inspection, so long as the inspection minimizes business impact. Failure to do is is considered a misdemeanor.