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

Facts

  • Los Angeles Municipal Code § 41.49 required hotels and motels to collect detailed guest information (including identity, vehicle data, stay dates, room number, rate, and payment method).
  • Operators had to keep the guest register on-site for 90 days in the reception/check-in area.
  • The ordinance required operators to make the register available to Los Angeles police officers for on-demand inspection, at a time and in a manner intended to minimize business interference.
  • Noncompliance was a misdemeanor punishable by up to six months’ imprisonment and a $1,000 fine.
  • Hotel operators and a lodging association brought a § 1983 action alleging the on-demand, warrantless inspection provision violated the Fourth Amendment.
  • The district court and an initial Ninth Circuit panel rejected the claim; the en banc Ninth Circuit reversed, holding the ordinance unconstitutional for lack of an opportunity for precompliance judicial review.

Issues

  1. Whether facial challenges under the Fourth Amendment to statutes authorizing warrantless searches are categorically barred or disfavored.
  2. Whether § 41.49’s warrantless, officer-initiated, on-demand inspection of hotel guest records is unreasonable under the Fourth Amendment.
  3. Whether hotels qualify as a “closely regulated” industry permitting warrantless administrative inspections without ordinary Fourth Amendment safeguards.

Decision

  • The Supreme Court affirmed the en banc Ninth Circuit in a 5–4 decision (Justice Sotomayor).
  • The Court held that Fourth Amendment facial challenges to search-authorizing statutes are neither categorically barred nor especially disfavored.
  • The Court held § 41.49 facially unconstitutional because it compelled immediate production of records on threat of criminal penalty without any mechanism for precompliance review by a neutral decisionmaker.
  • The Court rejected treating hotels as a closely regulated industry for purposes of exempting the ordinance from ordinary Fourth Amendment requirements.
  • The Court emphasized the ruling did not invalidate the recordkeeping requirement itself and did not bar police access obtained through consent, a warrant or subpoena with review, or recognized warrant exceptions.
  • Facial Fourth Amendment challenges to statutes authorizing searches are available; review focuses on the searches the law authorizes, not searches justified by independent doctrines (e.g., consent or exigency).
  • Administrative inspection regimes generally must provide the target an opportunity for precompliance review before a neutral decisionmaker.
  • A scheme that authorizes immediate, warrantless inspection and threatens criminal sanctions for refusal, without a meaningful avenue to contest the demand before punishment, is unreasonable under the Fourth Amendment.
  • The “closely regulated industry” exception is limited; courts should not extend it absent a demonstrated, inherent, and significant risk to public welfare comparable to historically recognized industries.

Conclusion

The Court held that Los Angeles’s ordinance authorizing warrantless, on-demand inspections of hotel guest registries was facially invalid because it lacked precompliance review before a neutral decisionmaker, and it confirmed that facial challenges to Fourth Amendment search regimes are permissible.