1. Did Dr. Ortega have a reasonable expectation of privacy, at least as to his desk and file cabinets?
2. Why didn’t the Supreme Court require that the employer have a warrant based on probable cause to search an employee’s desk and files when investigating work-related misconduct?
3. What did the Court decide in this case?

[The respondent, Dr. Magno Ortega, a physician and psychiatrist, was an employee of a state hospital and had primary responsibility for training physicians in the psychiatric residency program. Hospital officials, including the executive director of the hospital, Dr. Dennis O'Connor, became concerned about possible improprieties in Dr. Ortega's management of the program, particularly with respect to his acquisition of a computer and charges against him concerning sexual harassment of female hospital employees and inappropriate disciplinary action against a resident. In 1981, while Dr. Ortega was on administrative leave pending investigation of the charges, hospital officials, allegedly to inventory and secure state property, searched his office and seized personal items from his desk and file cabinets that were used in administrative proceedings resulting in his discharge. No formal inventory of property in the office was ever made, and all the other papers in the office were merely placed in boxes for storage. Dr. Ortega filed an action against the hospital officials under 42 U.S.C. Section 1983, alleging that the search of his office violated the Fourth Amendment. On cross-motions for summary judgment, the district court granted judgment for the hospital, concluding that the search was proper because there was a need to secure state property in the office. Affirming in part, reversing in part, and remanding the case, the court of appeals concluded that Dr. Ortega had a reasonable expectation of privacy in his office and that the search violated the Fourth Amendment. The court held that the record justified a grant of partial summary judgment for him on the issue of liability for the search, and it remanded the case to the district court for a determination of damages. The Supreme Court granted certiorari.]
O'CONNOR, J.…

… We accept the conclusion of the Court of Appeals that Dr. Ortega had a reasonable expectation of privacy at least in his desk and file cabinets….

In our view, requiring an employer to obtain a warrant whenever the employer wished to enter an employee's office, desk, or file cabinets for a work-related purpose would seriously disrupt the routine conduct of business and would be unduly burdensome….

The governmental interest justifying work-related intrusions by public employers is the efficient and proper operation of the workplace. Government agencies provide myriad services to the public, and the work of these agencies would suffer if employers were required to have probable cause before they entered an employee's desk for the purpose of finding a file or piece of office correspondence. Indeed, it is difficult to give the concept of probable cause, rooted as it is in the criminal investigatory context, much meaning when the purpose of a search is to retrieve a file for work-related reasons. Similarly, the concept of probable cause has little meaning for a routine inventory conducted by public employers for the purpose of securing state property…. To ensure the efficient and proper operation of the agency, therefore, public employers must be given wide latitude to enter employee offices for workrelated, non-investigatory reasons.
We come to a similar conclusion for searches conducted pursuant to an investigation of workrelated employee misconduct. Even when employers conduct an investigation, they have an interest substantially different from "the normal need for law enforcement." New Jersey v. T.L.O., supra, 469 U.S.
at 351, 105 S. Ct., at 748 (BLACKMUN, J., concurring in judgment). Public employers have an interest in ensuring that their agencies operate in an effective and efficient manner, and the work of these agencies inevitably suffers from the inefficiency, incompetence, mismanagement, or other work-related misfeasance of its employees. Indeed, in many cases, public employees are entrusted with tremendous responsibility, and the consequences of their misconduct or incompetence to both the agency and the public interest can be severe. In contrast to law enforcement officials, therefore, public employers are not enforcers of the criminal law; instead, public employers have a direct and overriding interest in ensuring that the work of the agency is conducted in a proper and efficient manner. In our view, therefore, a probable cause requirement for searches of the type at issue here would impose intolerable burdens on public employers. The delay in correcting the employee misconduct caused by the need for probable cause rather than reasonable suspicion will be translated into tangible and often irreparable damage to the agency's work, and ultimately to the public interest….
Balanced against the substantial government interests in the efficient and proper operation of the workplace are the privacy interests of government employees in their place of work which, while not insubstantial, are far less than those found at home or in some other contexts. As with the building inspections at Camara, the employer intrusions at issue here "involve a relatively limited invasion" of employee privacy. 387 U.S., at 537, 87 S.Ct., at 1735. Government offices are provided to employees for the sole purpose of facilitating the work of an agency. The employee may avoid exposing personal belongings at work by simply leaving them at home.
In sum, we conclude that the "special needs, beyond the normal need for law enforcement make the … probable-cause requirement impracticable,"
469 U.S., at 351, 105 S.Ct., at 748 (BLACKMUN, J., concurring in judgment), for legitimate workrelated, noninvestigatory intrusions as well as investigations of work-related misconduct. A standard of reasonableness will neither unduly burden the efforts of government employers to ensure the efficient and proper operation of the workplace, nor authorize arbitrary intrusions upon the privacy of public employees. We hold, therefore, that public employer intrusions on the constitutionally protected privacy interests of government employees for noninvestigatory, work-related purposes, as well as for investigations of work-related misconduct, should be judged by the standard of reasonableness under all circumstances. Under this reasonableness standard, both the inception and the scope of the intrusion must be reasonable:
"Determining the reasonableness of any search involves a twofold inquiry: first, one must consider 'whether the…. action was justified at its inception.' Terry v. Ohio, 392 U.S. [1], at 20 [88 S.Ct. 1868, 1879, 20 L.Ed.2d 889 (1968)]; second, one must determine whether the search as actually conducted 'was reasonable related in scope to the circumstances which justified the interference in the first place,' ibid." New Jersey v. T.L.O., supra, at 341,105 S.Ct., at 742-743.