In the case of Camara v. Municipal Court of the City and County of San Francisco, 1966, the U.S Supreme Court ruled that municipal health and safety inspections are subject to Fourth Amendment protections against unreasonable searches and seizures. The case arose when a tenant named Alphonso Camara refused entry to a housing inspector without a search warrant in violation of local law. He was subsequently charged with violating this law but argued that it violated his constitutional rights under the Fourth Amendment. The court agreed with him, holding that such inspections were indeed "searches" within the meaning of the amendment because they intruded upon personal privacy rights protected by it. Therefore, absent consent or emergency circumstances, officials must obtain warrants before conducting these types of administrative searches.

In the dissenting opinion for Camara v. Municipal Court of the City and County of San Francisco, Justice Clark argued that administrative searches should not be subject to Fourth Amendment protections because they are fundamentally different from criminal investigations. He contended that housing inspections are routine procedures aimed at ensuring public safety rather than seeking evidence of a crime, thus do not infringe upon personal privacy in the same way as criminal searches. Furthermore, he expressed concern that requiring warrants for such inspections would place an undue burden on administrative agencies and potentially hinder their ability to protect public health and safety effectively. Justice Clark also noted historical precedent supporting his view: warrantless administrative inspections had been widely accepted practice since colonial times without significant controversy or perceived infringement on civil liberties.