From     Berry v. Leslie (11th Cir. Sept. 16, 2014):  
      It was a scene right out of a Hollywood movie. On Aug. 21,      2010, after more than a month of planning, teams from the      Orange County Sheriffs Office descended on multiple target      locations. They blocked the entrances and exits to the      parking lots so no one could leave and no one could enter.      With some team members dressed in ballistic vests and masks,      and with guns drawn, the deputies rushed into their target      destinations, handcuffed the stunned occupants  and demanded      to see their barbers licenses. The Orange County Sheriffs      Office was providing muscle for the Florida Department of      Business and Professional Regulations administrative      inspection of barbershops to discover licensing violations.    
      We first held 19 years ago that conducting a run-of-the-mill      administrative inspection as though it is a criminal raid,      when no indication exists that safety will be threatened by      the inspection, violates clearly established Fourth Amendment      rights. See Swint v. City of Wadley, 51 F.3d 988 (11th      Cir. 1995). We reaffirmed that principle in 2007 when we held      that other deputies of the very same Orange County Sheriffs      Office who participated in a similar warrantless criminal      raid under the guise of executing an administrative      inspection were not entitled to qualified immunity. See      Bruce v. Beary, 498 F.3d 1232 (11th Cir. 2007). Today, we      repeat that same message once again. We hope that the third      time will be the charm.    
      The Fourth Amendment guarantees [t]he right of the people to      be secure in their persons, houses, papers, and effects,      against unreasonable searches and seizures. Its protections      apply to commercial premises, as well as to private homes.      In general, the Fourth Amendment requires a warrant supported      by probable cause to effectuate a constitutional search.      Indeed, this Court has explained, The basic premise of      search and seizure doctrine is that searches undertaken      without a warrant issued upon probable cause are `per se      unreasonable under the Fourth Amendmentsubject only to a few      specifically established and well-delineated exceptions.    
      One of those limited exceptions involves administrative      inspections of closely regulated industries. Because an      owner or operator of commercial property has a reduced      expectation of privacy in this context, the standard for      what may be reasonable under the Fourth Amendment is      correspondingly broader.    
      To fall within this exception, a warrantless inspection must      satisfy three criteria: (1) a `substantial government      interest [must] inform[] the regulatory scheme pursuant to      which the inspection is made; (2) the inspection must be      necessary to further [the] regulatory scheme; and (3) the      statutes inspection program, in terms of the certainty and      regularity of its application, [must] provid[e] a      constitutionally adequate substitute for a warrant. The      regulatory statute must [also] be sufficiently comprehensive      and defined such that it limits the discretion of      inspecting officers. Where a statute authorizes the      inspection but makes no rules governing the procedures that      inspectors must follow, the Fourth Amendment and its various      restrictive rules apply.    
      But even when the criteria set forth above are met, to      satisfy the Fourth Amendment, an administrative inspection      must be appropriately limited in both scope and execution      and may not serve as a backdoor for undertaking a warrantless      search unsupported by probable cause. Above all, such      inspections may never circumvent the Fourth Amendments      requirement for reasonableness. In this regard, an      administrative screening search must be as limited in its      intrusiveness as is consistent with satisfaction of the      administrative need that justifies it.    
      As detailed earlier, the regulatory framework for barbershop      inspections in Florida is embodied in Fla. Stat.  476.184      and its implementing rules. In particular,  476.184 requires      all barbershops to have a license issued by the DBPR and      directs the Florida Barbers Board to adopt rules governing      the operation and periodic inspection of barbershops      licensed in Florida. Rule 61G3-19.015(1), Fla. Admin. Code,      in turn, provides that the DBPR may conduct inspections      biennially on a random, unannounced basis. The regulatory      framework, which sets forth who may conduct such inspections,      notifies barbers that only the DBPR is so authorized. In this      case, no one disputes that the DBPR possesses statutory      authority to conduct warrantless inspections of barbershops,      nor do the parties assert that the statute authorizing such      inspections is constitutionally impermissible.    
      Instead, the plaintiffs contend that the search of Strictly      Skillz, which they allege was undertaken with an inordinate      display of force, failed to conform to the Fourth Amendments      requirement for reasonableness. Because we have twice held,      on facts disturbingly similar to those presented here, that a      criminal raid executed under the guise of an administrative      inspection is constitutionally unreasonable, we agree.    
      Unlike previous inspections of Strictly Skillz, which were      all conducted by a single DBPR inspector without the aid of      law enforcement, the August 21 search was executed with a      tremendous and disproportionate show of force, and no      evidence exists that such force was justified. Despite the      fact that neither OCSO nor the DBPR had any reason to believe      that the inspection of Strictly Skillz posed a threat to      officer safety, the record indicates that several OCSO      officers entered the barbershop wearing masks and bulletproof      vests, and with guns drawn; surrounded the building and      blocked all of the exits; forced all of the children and      other customers to leave; announced that the business was      closed down indefinitely; and handcuffed and conducted      pat-down searches of the employees while the officers      searched the premises. Such a search, which bears no      resemblance to a routine inspection for barbering licenses,      is certainly not reasonable in scope and execution. Rather,      [i]t is the conduct of officers conducting a raid.    
Continued here:
Volokh Conspiracy: When administrative inspections of businesses turn into massive armed police raids