In the case of Marshall, Secretary of Labor, et al. v. Barlow's Inc., 1977, the U.S Supreme Court ruled that warrantless Occupational Safety and Health Administration (OSHA) inspections violated the Fourth Amendment rights against unreasonable searches and seizures. The case arose when an OSHA inspector attempted to conduct a routine inspection at Barlow's electrical and plumbing installation business in Pocatello, Idaho without a search warrant or any specific evidence of an existing violation. When Mr. Ferrol G. "Bill" Barlow refused entry due to lack of a search warrant, he was subsequently cited by OSHA for denying the inspection under section 8(a) of Occupational Safety and Health Act which allowed for such inspections without warrants or consent from employers.The court held that administrative agencies like OSHA must obtain either consent or an administrative search warrant before conducting workplace safety inspections.

In the dissenting opinion for Marshall, Secretary of Labor, et al. v. Barlow's Inc., Justice White argued that warrantless inspections were necessary to enforce Occupational Safety and Health Act (OSHA) regulations effectively. He contended that requiring warrants would significantly impede OSHA’s ability to conduct surprise inspections and prevent employers from concealing or correcting violations before inspectors arrive. Furthermore, he pointed out that many other industries are subject to similar administrative searches without a warrant requirement due to their long history of government oversight or because they engage in businesses affecting public health or safety - such as liquor establishments or firearm dealerships - thus making it inconsistent not allowing the same for OSHA inspections. Lastly, he emphasized that if an employer refuses entry, obtaining a warrant could be time-consuming and burdensome which might further delay the inspection process thereby undermining its effectiveness.