## Facts

- Congress enacted the Federal Mine Safety and Health Act of 1977, requiring frequent, unannounced inspections of underground and surface mines to enforce health and safety standards and confirm correction of prior violations.
- Section 103(a) authorizes federal mine inspectors to enter mines without a warrant and without advance notice; if entry is refused, the Secretary of Labor may seek injunctive relief in federal court.
- A federal inspector attempted a follow-up inspection of stone quarry operations after prior violations had been identified.
- A company officer refused to permit the inspection to proceed without a warrant.
- The Secretary of Labor sued to enjoin the operator from refusing warrantless inspections required by § 103(a).
- The federal district court granted summary judgment for the operator, holding the warrantless inspection provision unconstitutional under the Fourth Amendment.
- The Secretary of Labor appealed, and the Supreme Court reviewed whether § 103(a)’s warrantless inspections are consistent with the Fourth Amendment.

## Issues

1. Whether warrantless inspections of mines authorized by § 103(a) of the Federal Mine Safety and Health Act of 1977 constitute unreasonable searches under the Fourth Amendment.

## Decision

- The Supreme Court reversed the district court.
- The Court held that warrantless inspections mandated by § 103(a) are reasonable under the Fourth Amendment.
- The Court concluded that mining is a closely regulated industry and that the Mine Act’s inspection program provides a constitutionally adequate substitute for a warrant.

## Legal Principles

- Warrantless administrative inspections of commercial property may be reasonable under the Fourth Amendment where Congress reasonably determines they are necessary to further a regulatory scheme and the regulatory program is comprehensive and well-defined.
- In closely regulated industries, an operator’s expectation of privacy is reduced because the operator is on notice that periodic inspections will occur for specific regulatory purposes.
- A statutory inspection regime can substitute for a warrant when it limits official discretion through predictable application and clear standards concerning who may inspect, the purposes of inspection, and the expected regularity of inspections.
- A warrant requirement is less likely to be imposed where unannounced inspections are central to effective enforcement and the statute constrains time, place, and scope through defined inspection obligations.

## Conclusion

The Court upheld the Mine Act’s warrantless inspection scheme, holding that frequent, unannounced mine inspections in a pervasively regulated and hazardous industry are reasonable administrative searches because the statute’s structured inspection program supplies the protections ordinarily served by a warrant.


Donovan v. Dewey, 452 U.S. 594 (1981)