	Introduction

The United States Supreme Court in City of Ontario v. Quon overturned a federal appellate court decision which had held that officials in the City of Ontario, California engaged in an unconstitutional search and seizure when they acquired and read the contents of messages sent to and from a city police officer's city-provided pager. As for Quon's Fourth Amendment allegations, it held that while the officers had a reasonable expectation of privacy in their text messages, the City's intrusion was reasonable in its inception and scope. The panel found that the Stored Communications Act outlawed handing over the transcripts of the officer's pager messages to the City. Because the City had a legitimate work-related reason to conduct its search, the Court concluded that it was reasonable under either the O'Connor standard – that of Justice Scalia (a search that would be considered reasonable in a private-employer context) or that of the O'Connor plurality (a work-related purpose for a search not excessive in scope).
In City of Ontario v. Quon, the Supreme Court held that officials had acted reasonably when they reviewed transcripts of messages sent to and from Sergeant Quon's city-issued pager in order to determine whether service limits on the pager's use should be increased. The Court assumed, without deciding, that Quon had a reasonable expectation of privacy for Fourth Amendment purposes, but found that the search of the transcripts was reasonable.
In O'Connor v. Ortega, the Court had earlier split over the question of what test should be used to assess the reasonableness of a search of a public employee's work space. A plurality favored one test (work-related purpose for a search not excessively intrusive in scope); Justice Scalia another (search that would be considered reasonable in a private-employer context). In Quon, the Court declined to resolve the issue, but concluded that the search at issue was reasonable under either test.