The first case to reach the U.S. Supreme Court regarding government access to electronic communications was decided last year in City of Ontario v. Quon, 130 S.Ct. 2619. The granting of certiorari to hear the case, as well as the arguments before the Court, received substantial media coverage.1

Under such circumstances, it was easy to anticipate that the Court’s decision would likewise receive extensive coverage.2 If only the various rulings in the case were as easy to interpret as many in the media made it appear.

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