The use of mobile electronic devices such as Blackberries and iPhones has become so commonplace that one can hardly imagine a world without 24/7 connectivity. As common as these technologies have become, however, it was only in June 2010 that the U.S. Supreme Court had its first opportunity to examine a workplace policy allowing an employer to monitor employee electronic communications. In City of Ontario v. Quon the Court upheld a city’s search of a SWAT officer’s text messages for compliance with its electronic communications policy.