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The following year, 1987, the Supreme Court had first dealt with the Fourth Amendment rights of government employees under administrative investigation in O'Connor v. Ortega, a case arising from the search of a supervising physician's office and records at a California public hospital. By a 5 4 margin the court had ruled that while public employees had Fourth Amendment protections, the search was reasonable and constitutional and that other such warrantless searches of public employees' belongings or workspace, where applicable, were similarly permissible as long as they were reasonably work related in inception and scope.[9].

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