In the case of Frank v. Maryland, the U.S. Supreme Court ruled in 1958 that a Baltimore city health inspector had not violated resident Roland C. Frank's Fourth Amendment rights by entering his property without a search warrant to inspect for rat infestation. The court held that municipal health inspections did not constitute unreasonable searches and seizures under the Fourth Amendment as they were necessary for public safety and welfare, thus differing from criminal investigations which required warrants due to their intrusive nature. This decision was later overruled by Camara v Municipal Court (1967), which established that administrative searches do require warrants.

In the dissenting opinion for Frank v. Maryland, Justice Douglas argued that a municipal health inspection without a warrant violated the Fourth Amendment's protection against unreasonable searches and seizures. He contended that such inspections were invasive and could be used as an excuse to harass citizens or invade their privacy under the guise of public safety. Douglas believed there should be clear standards in place to determine when an inspection is necessary, rather than leaving it up to individual inspectors' discretion. He also emphasized that obtaining warrants would not significantly hinder public health efforts since they can usually be obtained quickly if there is probable cause of a violation.