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 Administrative searches are permissible without a warrant when: 1) a substantial government interest informs the regulatory scheme under which the search is made; 2) the search is necessary to further the regulatory scheme; and 3) the statute's inspection program is a 'constitutionally adequate substitute for a warrant.' New York v. Burger, 482 U.S. 691, 702-04, 107 S. Ct. 2636, 96 L. Ed. 2d 601 (1987) (warrantless administrative inspection of premises of closely regulated business) (citing Donovan v. Dewey, 452 U.S. 594, 600-04, 101 S. Ct. 2534, 69 L. Ed. 2d 262 (1981) and United States v. Biswell, 406 U.S. 311, 315, 92 S. Ct. 1593, 32 L. Ed. 2d 87 (1972)). See also Michigan v. Tyler, 436 U.S. 499, 507-12, 98 S. Ct. 1942, 56 L. Ed. 2d 486 (1978) (administrative inspection of fire-damaged premises to determine cause of the fire); Camara v. Municipal Court of City and County of San Francisco, 387 U.S. 523, 534-39, 87 S. Ct. 1727, 18 L. Ed. 2d 930 (1967) (administrative inspection to ensure compliance with city housing code is acceptable). 


These cases involve situations where 'special needs, beyond the normal need for law enforcement, make ...

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