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Distinctions Between Public and Private Sector Cases
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9th Cir adverse publicity agency alleged applied arbi arbitration awards arbitrator's behavior communication concluded constitutional constructive discharge Coos County damage decision discharge an employee discipline or discharge discrimination disputes drug duty E-mail messages E-mail monitoring E-mail policy E-mail privacy effect efficiency egregious electronic monitoring emphasis added employee's off-duty employer's reputation Employment Relations Board enforcement establish evidence federal sector Fourth Amendment grievant harm hostile work environment impact involving Kesselman Factors labor arbitration Lankford liability ment nexus requirement Ninth Circuit off-duty activity off-duty conduct off-duty misconduct offensive Oregon State Police Oregon Supreme Court PECBA ployee Portland Firefighters Association presumption of nexus private sector prohibited protected Public Employee Collective public policy exception public sector reasonable rule Senate sexual conduct sexual harassment statute Sundowner Offshore Services supervisor Tillamook School District tion Title VII U.S. Supreme Court Union violation Willamina workers workplace