City of Los Angeles v. Patel, 576 U.S. 409 (2015), was a United States Supreme Court case in which the Court held that a Los Angeles law, Municipal Code § 41.49, requiring hotel operators to retain records about guests for a 90-day period, is facially unconstitutional under the Fourth Amendment to the United States Constitution because it does not allow for pre-compliance review.
[4] In 2003, Naranjibhai and Ramilaben Patel and other hotel operators sued the city in the federal district court, alleging that the ordinance violated the Fourth Amendment.
The majority opinion held that "facial challenges under the Fourth Amendment are not categorically barred or especially disfavored" and cited cases such as Sibron v. New York and Chandler v. Miller.
Justice Antonin Scalia, joined by Roberts and Clarence Thomas, wrote a dissent to argue that such a warrantless search is permitted in this case because it satisfies the conditions of a regulatory scheme for a closely regulated business.
Justice Samuel Alito, joined by Thomas, filed a second dissent, listing five other scenarios where the law could be applied constitutionally.