Administrative Searches:
Police officers searched respondent vehicle dismantler's junkyard pursuant to N.Y. Veh. & Traf. Law § 415(a)(5), which required junkyard owners to maintain records for routine spontaneous inspections by police officers and state agents. In the course of their search, officers discovered stolen vehicles and parts in respondent's junkyard. On appeal from a decision holding that the statute and search were constitutional, the appellate court reversed upon a conclusion that the statute violated the Fourth Amendment because of its authorization of warrantless searches solely for the purpose of uncovering criminality. On grant of certiorari, the Court reversed the appellate court's judgment upon a finding that vehicle dismantlers were part of a closely regulated industry that carried a reduced expectation of privacy thereby lessening the application of Fourth Amendment warrant and probable cause requirements. In addition, the high incidence of motor vehicle theft rendered such inspections essential and amounted to a substantial state interest and hence the State was allowed to address the major social problem of car theft by the implementation of an administrative scheme. New York v. Burger, 482 U.S. 691 (1987).
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