City of L. A. v. Patel, 135 S. Ct. 2443

Los Angeles Municipal Code §41.49 requires hotels to record detailed guest information for 90 days and keep records on premises.
The records are to be available for inspection by LAPD on demand, with penalties for noncompliance.
Respondents (motel operators and a lodging association) challenged §41.49(3)(a) as facially unconstitutional under the Fourth Amendment.
District court ruled for the City; Ninth Circuit initially upheld, then en banc reversed, finding inspections are Fourth Amendment searches and unconstitutional without precompliance review.
Supreme Court held facial challenges to Fourth Amendment statutes can be brought and that §41.49(3)(a) is facially invalid for lacking precompliance review.
Court suggested precompliance-review mechanisms (administrative subpoenas with neutral review) could render inspections permissible; majority did not uphold the current regime.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Fourth Amendment facial challenges to statutes are permissible	City argues facial challenges are disfavored or unavailable	Patel contends facial challenges are viable under several precedents	Facial challenges to Fourth Amendment statutes are permissible
Whether §41.49(3)(a) is facially unconstitutional for lacking precompliance review	City contends no precompliance review is needed	Patel argues precompliance review is required for administrative searches	§41.49(3)(a) is facially unconstitutional for lacking precompliance review
Whether hotels are a closely regulated industry justifying warrantless searches	City asserts hotels are closely regulated and subject to reduced privacy expectations	Patel argues hotels are not inherently closely regulated	Hotels are not categorically closely regulated; regime fails Burger criteria
Whether the administrative-search framework can justify §41.49(3)(a)	City contends administrative-search theory supports precompliance alternatives	Patel suggests alternatives undermine effectiveness and privacy protections	Administrative-search framework cannot validate current on-demand inspections without precompliance review

Camara v. Municipal Court of City and County of San Francisco, 387 U.S. 523 (1967) (administrative searches; precompliance review required for reasonableness)
See v. Seattle, 387 U.S. 541 (1967) (administrative inspections; precompliance context)
Marshall v. Barlow's, Inc., 436 U.S. 307 (1978) (closely regulated industries; warrantless searches)
New York v. Burger, 482 U.S. 691 (1987) (closely regulated industries test; three criteria)
Planned Parenthood of Southeastern Pa. v. Casey, 505 U.S. 833 (1992) (facial challenges measured by impact on those restricted)
Sibron v. New York, 392 U.S. 40 (1968) (limitation on broad facial challenge when conduct is ambiguous)
Chandler v. Miller, 520 U.S. 305 (1997) (drug-test requirement; facial invalidation of broad regimes)
Payton v. New York, 445 U.S. 573 (1980) (entry into residence without warrant; reasonableness)
Arizona v. Gant, 556 U.S. 332 (2009) (per se unreasonableness of certain searches; exceptions)
Colonnade Catering Corp. v. United States, 397 U.S. 72 (1970) (administrative search entry by secretary or delegate)