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This Article begins with a very brief overview of fundamental Fourth Amendment principles and federal statutory regulation of electronic surveillance of communications. Part II consists of a detailed look at O'Connor v. Ortega, and the uncertainties the decision created in the law. Part III examines City of Ontario v. Quon, and analyzes what the Court did decide. Part IV examines the issues in Quon that the Court did not decide. Part V states my conclusions as to where the decision leaves the law. The Article ends with an "user's guide" to Quon, which outlines how litigants and judges should attempt to apply Quon if presented with a case involving privacy in the government or private sector workplace.



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