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A plurality of the United States Supreme Court held that a search of a governmental employee’s office, not strictly limited to work related purposes, must meet Fourth Amendment requirements. O’Conner v. Ortega, 480 U.S. 709, 107 S.Ct. 1492, 94 L.Ed.2d 714 (1987).


 Another exception to the general rule that administrative searches must be limited to the underlying safety purpose for which they were intended is in the area of “pervasively regulated industries”.

The Supreme Court has approved statutorily authorized administrative searches of historically regulated industry (auto “chop-shop”/junkyards) or diminished Fourth Amendment Safeguards, notwithstanding fact that underlying purpose of regulatory statute is enforcement of penal laws. The statute, however, must meet a three- pronged test. New York v. Burger, 482 U.S. 691, 107 S.Ct. 2636, 96 L.Ed.2d 601, 613-614 (1987).

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