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Law School Case Brief

Malley v. Briggs - 475 U.S. 335, 106 S. Ct. 1092 (1986)

Rule:

In an action brought under 42 U.S.C.S. § 1983, the same standard of objective reasonableness that is applied in the context of a suppression hearing defines the qualified immunity accorded an officer whose request for a warrant allegedly caused an unconstitutional arrest. Only where the warrant application is so lacking in indicia of probable cause as to render official belief in its existence unreasonable will the shield of immunity be lost.

Facts:

Respondents, a married couple who were prominent citiizens in the community, were arrested at their home shortly before six o'clock on the morning of March 19, 1981. They were taken to a police station, booked, held for several hours, arraigned, and released. Local and statewide newspapers published the fact that respondents had been arrested and charged with drug possession. The charges against respondents were subsequently dropped when the grand jury to which the case was presented did not return an indictment. Respondents brought an action under 42 U.S.C. § 1983 in the United States District Court for the District of Rhode Island charging, inter alia, that petitioner, the state police officer who had applied for warrants for their arrest, violated their rights under the Fourth and Fourteenth Amendments. The case was tried to a jury, and at the close of respondents' evidence, petitioner moved for and was granted a directed verdict.  The District Court's primary justification for directing a verdict was that the act of the judge in issuing the arrest warrants for respondents broke the causal chain between petitioner's filing of a complaint and respondents' arrest. The court also stated that an officer who believes that the facts stated in his affidavit are true and who submits them to a neutral magistrate may thereby be entitled to immunity under the "objective reasonableness" standard of Harlow v. Fitzgerald, 457 U.S. 800 (1982). The United States Court of Appeals for the First Circuit reversed and remanded for a new trial, holding that officers who seek arrest warrants were not entitled to immunity unless they have an objectively reasonable basis for believing that the facts alleged in the supporting affidavit were sufficient to establish probable cause. The United States Supreme Court granted certiorari in order to review the First Circuit's application of the "objective reasonableness" standard.

Issue:

Were police officers, who sought arrest warrants that resulted to an allegedly unconstitutional arrest, entitled to absolute immunity?

Answer:

No.

Conclusion:

The Court held that a police officer whose request for a warrant allegedly caused an unconstitutional arrest was not entitled to absolute immunity from liability under § 1983, but was entitled only to a qualified immunity which depended on the objective reasonableness of his actions in seeking the warrant. According to the Court, the officer will not be immune if, on an objective basis, the application was so lacking in indicia of probable cause that no reasonably competent officer would have concluded that a warrant should issue, but immunity should be recognized if officers of reasonable competence could disagree on this issue.

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