City of Los Angeles v. Patel, et al

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Evidence
  • Date Filed: June 22, 2015
  • Case #: 13–1175
  • Judge(s)/Court Below: Sotomayor, J., delivered the opinion of the Court, in which Kennedy, Ginsburg, Breyer, and Kagan, JJ., joined. Scalia, J., filed a dissenting opinion, in which Roberts, C.J., and Thomas, J., joined. Alito, J., filed a dissenting opinion, in which Thomas, J., joined.
  • Full Text Opinion

A city's statute that requires hotels to provide to police their guest registries without a warrant violates the Fourth Amendment.

Respondents, hotel owners, brought a suit against the City of Los Angeles for a local ordinance that mandates hotels to retain their records for 90 days on hotel property and be made available for inspection by the police department on demand, without a warrant. Petitioners argued that motels are “closely regulated” businesses and subject to warrantless inspections. Petitioners called the laws crucial to reduce criminal activity especially in so-called parking meter motels that charge by the hour and are often used for prostitution and other crimes.

The district court upheld the law, ruling that hotel owners have no expectation of privacy when it comes to their registries. The Ninth Circuit panel agreed, but on en banc review, the Ninth Circuit struck down the law. The court concluded "the search of hotel registries was plainly a search under the Fourth Amendment, and the ordinance was unconstitutional on its face because it did not provide for any pre-compliance judicial review."

The Supreme Court affirmed the Ninth Circuit panel decision, and held that facial challenges can be brought under the Fourth Amendment. The statute that required hotel operators to make their records available to the police on demand is facially unconstitutional because is unconstitutional in all of its applications. The court noted police will still be able to make surprise inspections by getting a warrant or in instances in which an officer suspects the hotel operator might tamper with the registry. AFFIRMED.

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