On one hand, the U.S. Supreme Court and numerous lower courts have recognized a constitutional right to privacy and a first amendment freedom of association right that limits the manager's ability to impose an across-the-board prohibition on workplace relationships. On the other hand, emerging theories of sexual harassment and the agency's need to prevent the development of a hostile and abusive work environment suggest the need to restrict certain co-worker relationships. In particular, police managers may be justified in imposing reasonable limitations on relationships between superior and subordinate employees in order to reduce the potential for sexual harassment, avoid favoritism in job assignments, prevent morale problems, prevent a potentially dangerous situation stemming from divided loyalties, prevent potential conflicts of interest, and protect the department's reputation within the community. 37 notes