Naranjibhai Patel v. City of Los Angeles, 686 F.3d 1085

Patel plaintiffs operate motels in Los Angeles and challenge LAMC § 41.49 requiring guest registry records and police access; bench trial on stipulated evidence; district court held the ordinance reasonable and rejected privacy objections.
LAMC § 41.49 defines hotel broadly and requires recording guest information (name, address, guests, vehicle details, arrival/departure times, room number, payment details, employee name) and keeping records on premises for 90 days.
Records may be kept in electronic or paper form and must be printable if electronic.
Police may inspect the records on request, with inspection to minimize business interference.
Patels stipulated that records are searched/seized by police under the ordinance without consent or a warrant, forming the sole trial issue whether the ordinance is facially constitutional.
Court reviews Fourth Amendment challenges de novo and addresses reasonable expectation of privacy and common-law trespass concepts as applied to hotel guest registers.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether hotel guest registry information is protected by a reasonable expectation of privacy	Patel argues registries are private business records.	City contends hotel operators lack a privacy interest in guest information.	No reasonable expectation of privacy found; facial challenge fails.
Whether hotel owners have an objectively reasonable privacy interest in guest registers	Patel owners have privacy in their records.	No evidence hotel owners reasonably expect privacy in guest registers.	Patels fail to show a reasonable expectation of privacy.
Whether on-premises inspection of guest registers without a warrant is permissible as a search	Inspection without warrant intrudes without exception.	Inspection allowed under regulatory framework; minimizes business disruption.	Not an unconstitutional intrusion on its face; warrantless inspection upheld on facial challenge.
Whether the ordinance can be sustained as a facial challenge given Fourth Amendment standards	Regulation cannot pass under Fourth Amendment due to privacy interests.	Ordinance reasonably limits intrusion and targets information, not private space.	Facial challenge unsuccessful; ordinance not facially unconstitutional.

United States v. Salerno, 481 U.S. 739 (U.S. 1987) (facial challenge limits on constitutionality of a statute)
Washington State Grange v. Washington State Republican Party, 552 U.S. 442 (U.S. 2008) (principle for facial challenge standard)
United States v. Jones, 132 S. Ct. 945 (U.S. 2012) (touches on reasonable expectation of privacy and trespass concepts)
Soldal v. Cook County, 506 U.S. 56 (U.S. 1992) (reasonableness standard under Fourth Amendment)
Camara v. Municipal Court of San Francisco, 387 U.S. 523 (U.S. 1967) (reasonableness of inspections)
Miller v. United States, 425 U.S. 435 (U.S. 1976) (privacy in records when information disclosed to third parties)
United States v. Cormier, 220 F.3d 1103 (9th Cir. 2000) (hotel guest information not confidential in privacy sense)
New York v. Burger, 482 U.S. 691 (U.S. 1987) (closely regulated industry exception to warrantless inspections)
Tucson Woman’s Clinic v. Eden, 379 F.3d 531 (9th Cir. 2004) (heightened privacy expectations in medical-service context)
Marshall v. Barlow’s, Inc., 436 U.S. 307 (U.S. 1978) (premises privacy and inspection regimes)
New York v. Burger, (same as above) (U.S. 1987) (closely regulated industry framework)