City of L. A. v. Patel

Background

Respondents, a group of motel operators and a lodging association, sued the City of Los Angeles over a local rule that requires hotels to keep guest records (names, IDs, vehicle information, payment details, arrival and departure times, room numbers) and to make those records "available to any officer of the Los Angeles Police Department for inspection" on demand. Failure to comply is a misdemeanor punishable by jail and fines. The parties agreed to bring a facial Fourth Amendment challenge, and the case reached the Ninth Circuit en banc before coming to this Court.

Reasoning

The Court first held that facial challenges can be brought under the Fourth Amendment. It then focused on whether the on-demand inspection rule is reasonable. The majority assumed the rule serves an administrative public-safety purpose but concluded the ordinance is facially unconstitutional because it gives hotel operators no opportunity for precompliance review by a neutral decisionmaker before they face criminal penalties for refusing a police demand. The Court explained that administrative inspections may be allowed, but operators must be able to seek prompt review (for example, via administrative subpoenas or a motion to quash) so they are not forced to choose between immediate compliance and arrest. The Court also rejected treating hotels as a "closely regulated" industry that would allow broader warrantless searches here.

Real world impact

The decision prevents police from using this ordinance to demand guest registries on the spot without a review mechanism. Hotels must still keep records as required, and police retain other tools—consent, administrative subpoenas, warrants, or exigent‑circumstance searches—to obtain them. The ruling is narrow, leaving recordkeeping rules intact but requiring procedural protections before penalties apply.

Dissents or concurrances

Justices SCALIA and ALITO dissented, arguing hotels are historically and extensively regulated, many applications of the law would be constitutional, and a broad facial invalidation was unnecessary.