State of Vermont v. Welch
In State of Vermont v. Welch (1992) 160 Vt. 70 624 A.2d 1105, the Supreme Court of Vermont held that a criminal defendant had a privacy interest in her pharmaceutical records, based on a reasonable expectation that those records would not be arbitrarily disclosed. (Id., 624 A.2d at p. 1109.)
The court concluded, however, that the "'pervasively regulated industry'" exception to the warrant requirement allowed for the warrantless inspection of her records in furtherance of the enforcement of statutes pertaining to closely regulated businesses such as pharmacies. (Id. at pp. 1110-1111.)
The court specifically noted the state interest in the regulation of dangerous drugs (id. at p. 1111), and concluded the warrantless inspection of pharmacy records undertaken in compliance with statutory procedures was reasonable (id. at p. 1112).