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'Legislative schemes authorizing warrantless administrative searches of commercial property do not necessarily violate the Fourth Amendment.' Donovan v. Dewey, 452 U.S. 594, 101 S.Ct. 2534, 2538, 69 L.Ed.2d 262 (1981). Such searches are constitutionally valid, however, only if there is a substantial governmental interest that informs the regulatory scheme pursuant to which the inspection is made, if warrantless inspections are necessary to further the regulatory scheme, and if the inspection program provides a constitutionally adequate substitute for a warrant, in terms of the certainty and regularity of its application. New York v. Burger, 482 U.S. 691, 107 S.Ct. 2636, 2644, 96 L.Ed.2d 601 (1987). 


Search regimes where no warrant is ever required may be reasonable where “‘special needs . . . make the warrant and probable-cause requirement impracticable,’” Skinner, 489 U. S., at 619, 109 S. Ct. 1402, 103 L. Ed. 2d 639 (quoting Griffin v. Wisconsin, 483 U. S. 868, 873, 107 S. Ct. 3164, 97 L. Ed. 2d 709 (1987) (some internal quotation marks omitted)), and where the “primary purpose” of the searches is “[d]istinguishable from the general interest in crime control,” Indianapolis v. Edmond, 531 U. S. 32, 44, 121 ...

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