CT: Targeted zoning search requires individualized showing of administrative PC under Camara

The trial court properly determined that the inspection of the defendants’ property, which was not part of a periodic or area inspection program, was subject to the requirements of the Fourth Amendment. That court, however, did not apply the correct standard in making its finding of probable cause so the judgment granting the injunction was reversed. The trial court erred in concluding that the appropriate standard for determining probable cause is a showing of a valid public interest. The relaxed showing of Camara is limited to routine and area wide inspections and did not apply to the targeted search of the defendant’s property here, which demanded a more particularized showing of probable cause. Before a trial court may issue an order permitting a zoning officer to enter and search a particular property, there must be a preliminary showing of facts within the knowledge of the zoning officer and of which that officer has reasonably trustworthy information that are sufficient to cause a reasonable person to believe that conditions constituting a violation of the zoning ordinances are present on the subject property. Town of Bozrah v. Chmurynski, 303 Conn. 676, 36 A.3d 210 (2012).