In a decision that may have substantial repercussions on the enforcement of environmental protection statutes, the Supreme Court on May 23 declared in Marshall v. Barlow's, Inc.¹ that a provision of the Occupational Safety and Health Act² authorizing warrantless inspections of workplace premises for safety hazards³ violates the Fourth Amendment. The majority opinion, written by Justice White, attempted to limit the Court's holding to the unique facts in the case, but the constitutional logic of the decision seems equally applicable to other statutes that provide for various forms of warrantless inspections to seek out violations. In particular, the constitutionality of enforcement provisions in several environmental statutes may be called into question under Barlow's, with the result being the imposition of a substantial burden upon the enforcement efforts of the Environmental Protection Agency (EPA).