States Dist. Court, 407 U.S. 297, 313, 92 S.Ct. 2125, 32 L.Ed.2d 752 (1972). The Supreme Court has recognized that “searches and seizures inside a home without a warrant are presumptively unreasonable.” Payton v. New York, 445 U.S. 573, 586, 100 S.Ct. 1371, 63 L.Ed.2d 639 (1980). However, the Supreme Court has permitted exceptions to the warrant requirement when “special needs, beyond the normal need for law enforcement, make the warrant and probable-cause requirement impracticable.” New Jersey v. T.L.O., 469 U.S. 325, 351, 105 S.Ct. 733, 83 L.Ed.2d 720 (1985) (Blackmun, J., concurring in judgment) (allowing school officials to conduct warrantless searches of student property without probable cause); see also O’Connor v. Ortega, 480 U.S. 709, 107 S.Ct. 1492, 94 L.Ed.2d 714 (1987) (<HOLDING>); Griffin v. Wisconsin, 483 U.S. 868, 873-74,
holding searches conducted without a warrant based on probable cause are presumptively unreasonable holding neither the warrant requirement nor the probable cause requirement should apply to noninvestigatory workrelated purposes or for investigations of workrelated misconduct  holding a person may consent to warrantless searches as a condition of a suspended sentence holding  1983 action lies for warrantless arrest without probable cause holding that government employers may conduct warrantless workrelated searches of employees offices without probable cause