Supreme Court Decision: City of Los Angeles v. Patel – Hotels Not Required to Provide Guest Info to Police Upon Request

At issue in this case was whether a city can authorize the police to routinely inspect hotel guest registries without any individualized suspicion or judicial supervision.  Los Angeles had a Municipal Code provision that that requires hotels to collect names, drivers licenses, vehicle information, payment information, and length of stay for every hotel guest, hold them for 90 days, and requires them to share this with the police without a warrant or any judicial review.

A group of motel owners sued, arguing that the statute, on its face, violated the Fourth Amendment.  The Fourth Amendment has long allowed people to meet at hotels for political and religious purposes without being subject to police inspections.  The trial court held that the Fourth Amendment was not violated by the ordinance, as did a 3 judge panel of the Ninth Circuit.  However, the Ninth Circuit heard the case en band, and reversed.  The Supreme Court upheld this decision.  It held that although a warrant isn’t necessarily required, some pre-compliance judicial review must take place.

You can read the full text of the decision here: http://www.supremecourt.gov/opinions/14pdf/13-1175_2qe4.pdf.