Platteville Area Apartment Assn., et al., v. City of Platteville
United States Court of Appeals for the Seventh Circuit
179 F.3d 574 (1999)
The City of Platteville (defendant) adopted ordinances allowing periodic rental-housing inspections for health and safety code violations, with administrative warrants available if a landlord or tenant refused inspection, but its building inspector used those warrants — issued only to search for chapter 23 health and safety violations — to also search closets and bureaus specifically looking for violations of a separate chapter 22 rule limiting occupancy to four unrelated people per single-family dwelling. The Platteville Area Apartment Association (plaintiffs) sued to enjoin the inspection ordinance under the Fourth Amendment, and the district court granted partial relief, finding the warrants didn't authorize the multiple-occupancy searches; both sides appealed.
Whether, under the Fourth Amendment, an agency is authorized to conduct an administrative search for potential violations not listed in the administrative warrant it obtained.