In the case of New York v. Burger, 1986, the US Supreme Court ruled in favor of New York State's law that allowed warrantless inspections of automobile junkyards and vehicle dismantling operations. The court held that these industries were closely regulated enough to diminish operators' expectation of privacy. Leo Burger, a junkyard owner who was found with stolen vehicles during such an inspection, argued this violated his Fourth Amendment rights against unreasonable searches and seizures. However, the court decided that while warrantless administrative searches do infringe upon owners' Fourth Amendment rights, they are permissible if a substantial government interest exists; if the search is necessary to furthering regulatory scheme; and if there is certainty providing a constitutionally adequate substitute for a warrant (i.e., informing business owners their premises will be subject to periodic inspections). In this context it was deemed reasonable due to state’s interest in regulating businesses potentially involved in criminal activity.

In the dissenting opinion for New York v. Burger, Justice Brennan argued that the search of a junkyard without a warrant violated the Fourth Amendment's protection against unreasonable searches and seizures. He contended that while certain industries may be subject to administrative inspections due to their public safety risks, this does not apply universally and should not extend to automobile junkyards as they do not pose an immediate threat or danger. Furthermore, he disagreed with the majority's view that vehicle dismantling is closely regulated industry which would justify warrantless searches under previous precedents set by cases like Colonnade Catering Corp v United States. In his view, such regulation was intended primarily for record-keeping purposes rather than facilitating unannounced inspections. Therefore, he believed it was inappropriate to use these regulations as justification for bypassing constitutional protections against unwarranted government intrusion.