despite the Court's Cohen v. California holding that such behavior could not sustain a prosecution for disorderly conduct. The Court had also upheld the Hatch Act's limitations on political activity by federal employees on several occasions, she noted. Those past cases, O'Connor continued, had shown deference to the government's opinion of what speech acts by employees in the workplace would be disruptive to the government's interest in providing public services efficiently, again in ways the Court had not with cases concerning speech in general. The Seventh Circuit's requirement "would force the government employer to come to its factual conclusions through procedures that substantially mirror the evidentiary rules used in court", O'Connor wrote. Hearsay evidence might not be usable, and credibility judgements might not be shared by a jury or judge. Yet both were regularly used by both public and private employers in making personnel decisions. "Government employers should be allowed to use [them], without fear that these differences will lead to liability." What O'Connor did allow was that the public employer's decision must be the result of "the care that a reasonable manager would use before making an employment decision". She again responded to Scalia, who had said precedent made that standard applicable only where the employment had some sort of contractual basis and was not at-will or probationary. "We believe that the possibility of inadvertently punishing someone for exercising her First Amendment rights makes such care necessary." She then addressed Stevens' claim in dissent that this was less protection than the Court had required for lesser rights. "We have never held that it is a violation of the Constitution for a government employer to discharge an employee based on substantively incorrect information. Where an employee has a property interest in her job, the only protection we have found the Constitution gives her is a right to adequate procedure." Applying this analysis to the facts of the case, she concluded that hospital management had made a reasonable decision of what Churchill had said before firing her. And what they believed Churchill to have said, under Connick, was disruptive enough to justify adverse action regardless of whether it addressed a public concern, which the plurality declined to decide. "Discouraging people from coming to work for a department certainly qualifies as disruption." Perkins-Graham herself had told Davis she didn't think the hospital could "tolerate that kind of negativism" much longer, and if