The Fourth Amendment to the U.S. Constitution protects citizens against unreasonable searches and seizures of their persons, houses, papers, and effects. However, this protection limits governmental searches and seizures only-citizens are not guaranteed protection from unreasonable searches and seizures conducted by private citizens or organizations. The central issue in O'Connor v. Ortega (1987) [Page 599]was whether officials at a public hospital violated a doctor's Fourth Amendment rights. The Supreme Court held that public employees have reasonable expectations of privacy in their offices and that their employers must meet strict criteria to conduct legal searches of these areas.