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Media > Newsletters > Law Enforcement Bulletin > July 2015 > Search and Seizure (Hotel Guest Registries): City of Los Angeles v. Patel

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Search and Seizure (Hotel Guest Registries): City of Los Angeles v. Patel

Question: Does a municipal code that allows police to inspect hotel guest records on demand violate the Fourth Amendment?

Quick Answer: Yes. An administrative warrant is required.
City of Los Angeles v. Patel, United States Supreme Court, June 22, 2015

Facts: A Los Angeles municipal code required hotel operators to record and keep information about their guests on the premises and to make the records available to “any officer of the Los Angeles Police Department for inspection” on demand. If hotel operators failed to make these records available to the police, they could be arrested and charged with a misdemeanor for violating the code. The information included the guest’s name and address, the number of people in the party, the make, model and license plate of each car, the date and time of arrival and scheduled departure date, the room number, rate charged, and method of payment.

Importance: Searches without warrants are per se unreasonable under the Fourth Amendment. Under the facts of the case, the administrative exception to the warrant requirement did not apply, nor did consent or exigency.

Keep in Mind: The Supreme Court emphasized that the ruling was very narrow. The rest of the record-keeping law stands and police can still examine the records so long as they are complying with the Fourth Amendment. They just can’t search without affording the owner a chance to have the request reviewed. The exception for exigent circumstances still allows police to effectuate quick searches.