City Of Los Angeles v. Patel

135 S.Ct. 2443 (2015)

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Nature of the Case

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Facts

D requires hotel operators (Patel (P) to record information about their guests, including: the guest’s name and address; the number of people in each guest’s party; the make, model, and license plate number of any guest’s vehicle parked on hotel property; the guest’s date and time of arrival and scheduled departure date; the room number assigned to the guest; the rate charged and amount collected for the room; and the method of payment. Guests without reservations, those who pay for their rooms with cash, and any guests who rent a room for less than 12 hours must present photographic identification at the time of check-in, and hotel operators are required to record the number and expiration date of that document. The records must be maintained for 90 days. These records are to be made available to any police officer for inspection. Failure to comply by P was a misdemeanor with up to six months in jail and a $1000 fine. Ps facially challenged the ordinance. D got the judgment because P lacked a reasonable expectation of privacy in the records subject to inspection. P appealed and eventually, the Court of Appeals reversed. It reasoned the records were private property and thus it was a Fourth Amendment search and was unreasonable because Ps were not given an opportunity to ‘obtain judicial review of the reasonableness of the demand prior to suffering penalties for refusing to comply. D appealed.