In the case Donovan, Secretary of Labor, et al. v. Lone Steer, Inc., 1983, the U.S Supreme Court ruled on whether a warrantless administrative search by Occupational Safety and Health Administration (OSHA) inspectors violated the Fourth Amendment rights of a business owner. The court held that businesses do not have an expectation of privacy that would necessitate a warrant for such inspections under normal circumstances because they are subject to regular oversight from regulatory agencies like OSHA. However, in this particular instance where there was no imminent danger or ongoing violation but rather an inspection based on an employee complaint about safety conditions at Lone Steer's restaurant-bar in North Dakota; it was determined that obtaining a warrant is necessary before conducting such searches unless consent is given by the business owner or exigent circumstances exist which justify immediate action without waiting for judicial approval.

In the dissenting opinion for Donovan, Secretary of Labor, et al. v. Lone Steer, Inc., Justice O'Connor argued that the majority's decision to uphold warrantless administrative searches in closely regulated industries was overly broad and threatened Fourth Amendment protections against unreasonable searches and seizures. She contended that such a ruling could potentially extend to any business subject to pervasive government regulation or licensing requirements - not just those traditionally considered "closely regulated." Furthermore, she disagreed with the majority's assertion that businesses operating within these sectors have a reduced expectation of privacy due to their regulatory environment. Instead, she maintained that all citizens should enjoy equal protection under the Fourth Amendment unless they voluntarily relinquish this right through informed consent or by engaging in illegal activities.