Camara v. Municipal Court Case Brief

Camara v. Municipal Court, 387 U.S. 523, 87 S. Ct. 1727 (1967)

FACTS: On November 6, 1963, a Housing inspector (Health Department) entered an apartment building for a routine annual inspection. The building manager told him that Camara, who leased the ground floor, was living in part of the space, which was not authorized for residential usage. The inspector confronted Camara and was refused entry to the space. Two days later, the inspector returned, and was again denied entry. A citation was mailed to Camara, and he failed to appear at the district attorney’s office, as ordered. Two weeks later, two more inspectors again visited Camara and informed him that he was in violation of the law.

Camara was charged with violating a California law requiring him to permit warrantless inspections of his residence by housing inspectors. He was arrested and filed a writ of prohibition on the charge. The lower courts, basing their opinion on earlier Supreme Court rulings, upheld the charge against Camara.

ISSUE: May the law require warrantless inspections of property?

HOLDING: No

DISCUSSION: While the Court held that allowing such warrantless inspections to be a violation of the Fourth Amendment, the Court agreed that the needs of the community for safety might outweigh the blanket prohibition on such searches. The Court agreed that “area inspections” might be appropriate, and defined that search as designating an area in need of inspection services and requesting a blanket warrant for that area. The appropriate standard may be based upon the passage of time, the nature of the building or the condition of the entire area. The Court stated that:

“The warrant procedure is designed to guarantee that a decision to search private property is justified by a reasonable governmental interest. But reasonableness is still the ultimate standard. If a valid public interest justifies the intrusion contemplated, then there is probable cause to issue a suitably restricted search warrant. Such an approach neither endangers time-honored doctrines applicable to criminal investigations nor makes a nullity of the probable cause requirement in this area. It merely gives full recognition to the competing public and private interests here at stake and, in so doing, best fulfills the historic purposes behind the consituational right to be free from unreasonable government invasions of privacy.”