Friday, November 1, 2013

Camara v. Municipal Court case brief

Camara v. Municipal Court case brief summary
387 U.S. 523 (1967)

Petitioner occupant sought review of a judgment from the District Court of Appeal of California, First Appellate District, which affirmed the decision of the California superior court denying his request for a writ of prohibition. The occupant sought to enjoin criminal proceedings against him based upon his refusal to submit to a warrantless search of his apartment by a building inspector for respondent city.

A city ordinance gave city building inspectors the right to enter any building at reasonable times in furtherance of their code enforcement duties. The occupant denied entrance to building inspectors on three separate occasions, each time demanding that they first obtain a warrant. He was prosecuted under another ordinance that made it a crime to refuse to comply with the inspectors' requests. He claimed the warrantless search requested by the building inspectors violated his Fourth Amendment rights.

  • The Court agreed and, to the extent that its prior decision in Frank v. Maryland, 359 U.S. 360, permitted warrantless administrative searches, it overruled that decision. 
  • The Court held that the administrative search was not peripheral to the occupant's Fourth Amendment interests because a criminal prosecution could and did result from his refusal to submit. 
  • The Court held that probable cause would still be required for issuance of a warrant for an administrative search, but the standard was lower than for issuance of a warrant in criminal cases. 
  • The standard would be met by a reasonableness showing, in light of the reasonable goals of code enforcement.

The Court vacated the judgment of the California district court of appeal and remanded for further proceedings, including issuance of a writ of prohibition to the California criminal court.

Recommended Supplements for Administrative Law Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)

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