City of Los Angeles v. Patel

Summarized by:

  • Court: U.S. Supreme Court Certiorari Granted
  • Area(s) of Law: Constitutional Law
  • Date Filed: October 20, 2014
  • Case #: 13-1175
  • Judge(s)/Court Below: Court Below: 738 F.3d 1058 (9th Cir. 2013)
  • Full Text Opinion

Whether statutes or ordinances authorizing warrantless searches of hotel registries violate the Fourth Amendment, and whether a hotel has an expectation of privacy in their guest registry under the Fourth Amendment.

Respondents are motel owners who challenged the provision of Los Angeles Municipal Code §41.49, which authorizes any police officer to perform warrantless on-site inspections of their guest records.

A Ninth Circuit panel affirmed the ruling by the district court, which held that §41.49 is not unconstitutional on its face, but a rehearing en banc held that the municipal code provision to be facially invalid under the Fourth Amendment. The Supreme Court granted certiorari to resolve a split between the Ninth and Sixth Circuits on whether facial challenges to statutes and ordinances are permitted under the Fourth Amendment, and to determine whether a hotel has an expectation of privacy in their guest registry under the Fourth Amendment.

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