Kilgore v. City of South El Monte

Massage industry was a “closely regulated” industry in California and warrantless search of massage parlor came within exception to warrant requirement for an administrative search of a “closely regulated” business; three necessary requirements were met: curtailing prostitution and human trafficking is a substantial government interest; warrant exception is necessary to further the regulatory scheme considering the potential ease of concealing violations; the inspection program, in terms of the certainty and regularity of its application provided a constitutionally adequate substitute for a warrant.