Camara v. Municipal Court

Supreme Court of United States
387 U.S. 523 (1967)

ELI5:

Rule of Law:

The Fourth Amendment's prohibition against unreasonable searches and seizures applies to administrative inspections of private residences. While such inspections require a warrant for non-consensual entry, the 'probable cause' necessary to obtain an administrative warrant can be based on reasonable legislative or administrative standards for conducting an area-wide inspection, rather than specific knowledge of a violation in the particular dwelling.

Facts:

On November 6, 1963, a San Francisco health inspector entered an apartment building for a routine annual inspection.
The building manager informed the inspector that Roland Camara, the ground floor lessee, was using his leasehold as a personal residence, which the inspector believed violated the building's occupancy permit.
The inspector confronted Camara and demanded to be allowed to inspect the premises.
Camara refused to permit the inspection because the inspector did not have a search warrant.
The inspector returned on November 8 without a warrant, and Camara again refused entry.
Two inspectors returned a third time on November 22, informed Camara he was required by law to permit an inspection under § 503 of the Housing Code, but Camara again refused to allow access without a search warrant.

Procedural Posture:

A criminal complaint was filed charging Camara with refusing to permit a lawful inspection in violation of the San Francisco Housing Code.
Camara filed a petition for a writ of prohibition in a California Superior Court to halt the criminal prosecution, arguing the ordinance was unconstitutional.
The Superior Court, a court of first instance, denied the writ.
Camara, as appellant, appealed to the California District Court of Appeal, which affirmed the lower court's decision.
Camara's petition for a hearing before the Supreme Court of California, the state's highest court, was denied.
Camara then appealed to the United States Supreme Court, which noted probable jurisdiction to hear the case.

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Does a municipal ordinance that authorizes housing officials to conduct a warrantless inspection of a private residence, and makes it a criminal offense to refuse such an inspection, violate the Fourth Amendment's prohibition against unreasonable searches?

Opinions:

Majority - Mr. Justice White

Yes. The ordinance violates the Fourth Amendment because administrative searches are significant intrusions upon the interests protected by the Fourth Amendment, and except in certain carefully defined circumstances, a warrantless search of private property is unreasonable. The Court overruled its prior decision in Frank v. Maryland, holding that the Fourth Amendment's protections are not limited to searches for evidence of criminal activity. While a warrant is required, the standard of probable cause is different for administrative searches; it does not require specific evidence of a violation but can be satisfied by showing that the inspection is part of a reasonable legislative or administrative scheme based on factors like the passage of time, the nature of the building, or the condition of the area. This approach balances the individual's right to privacy against the public interest in health and safety.

Analysis:

This landmark decision expanded the scope of the Fourth Amendment by applying the warrant requirement to administrative searches, a context previously considered outside its purview. By rejecting the civil/criminal distinction for searches of private homes, the Court affirmed that privacy interests are paramount regardless of the government's purpose. The case is most significant for creating a new, more flexible standard of 'administrative probable cause,' which allows for systematic code enforcement without requiring individualized suspicion. This established a bifurcated approach to probable cause, preserving the strict standard for criminal investigations while enabling necessary public health and safety inspections through a less demanding warrant process.

Gunnerbot

AI-powered case assistant

Loaded: Camara v. Municipal Court (1967)

Try: "What was the holding?" or "Explain the dissent"