NO. In the Supreme Court of the United States CITY OF LOS ANGELES, Petitioner, v. NARANJIBHAI PATEL, RAMILABEN PATEL, LOS ANGELES LODGING ASSOCIATION, Respondents. On Petition for Writ of Certiorari to the United States Court of Appeals for the Ninth Circuit PETITION FOR WRIT OF CERTIORARI Michael N. Feuer City Attorney James P. Clark Chief Deputy City Attorney Thomas H. Peters Chief Assistant City Attorney Gregory P. Orland Deputy City Attorney Counsel Of Record Office Of The Los Angeles City Attorney 900 City Hall East 200 North Main Street Los Angeles, California 90012 213.978.7732
[email protected] Counsel for Petitioner Becker Gallagher · Cincinnati, OH · Washington, D.C. · 800.890.5001 i QUESTIONS PRESENTED FOR REVIEW I. To resolve a split between the Ninth and Sixth Circuits are facial challenges to ordinances and statutes permitted under the Fourth Amendment? II. To resolve a spilt between the Ninth Circuit and the Massachusetts Supreme Court, does a hotel have an expectation of privacy under the Fourth Amendment in a hotel guest registry where the guest supplied information is mandated by law and that ordinance authorizes the police to inspect the registry? If so, is the ordinance facially unconstitutional under the Fourth Amendment unless it expressly provides for pre-compliance judicial review before the police can inspect the registry? ii TABLE OF CONTENTS QUESTIONS PRESENTED FOR REVIEW ...... i TABLE OF AUTHORITIES.................. vii INTRODUCTION........................... 1 OPINIONS BELOW ......................... 2 JURISDICTION ............................ 2 APPLICABLE CONSTITUTIONAL, STATUTORY, AND ORDINANCE PROVISIONS........... 2 STATEMENT OF THE CASE ................. 2 A.Background ............................. 2 B.Facts................................... 3 REASONS FOR GRANTING THE PETITION ...