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Pearson v. Callahan

Supreme Court of the United States · Civil Procedure

Civil ProcedureTortsQualified ImmunityFourth AmendmentSection 1983qualified immunityFourth Amendmentwarrantless entry

Facts

A confidential informant told Utah narcotics officers that respondent had arranged to sell him methamphetamine. After the informant reentered respondent's trailer home, purchased methamphetamine while wearing a transmitter, and gave the prearranged arrest signal, officers entered through a porch door without a warrant, encountered respondent and others, and conducted a protective sweep. They recovered methamphetamine, the marked bill, and drug syringes. Respondent later sued under § 1983, claiming the warrantless entry violated the Fourth Amendment.

Issue

Whether courts must always follow Saucier's mandatory two-step sequence in qualified immunity cases before deciding whether a right was clearly established, and whether the officers here were entitled to qualified immunity because the unlawfulness of their warrantless entry was not clearly established at the time.

Rule

The Saucier two-step procedure is no longer mandatory; lower courts may exercise sound discretion in deciding which prong of qualified immunity to address first. An officer is entitled to qualified immunity unless the officer violated a clearly established constitutional right, and the clearly established inquiry turns on the objective legal reasonableness of the action in light of legal rules clearly established at the time.

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In Phoenix, Dana Ruiz sued Officer Kevin Morrow under § 1983, alleging a novel Fourth Amendment violation during a street detention. On summary judgment, the district judge concluded that existing precedent plainly did not clearly establish the asserted right, but the underlying constitutional issue was difficult, fact-specific, and unnecessary to the outcome.

How should the court proceed under the governing rule?

Explanation. Lower courts are no longer required to follow an inflexible merits-first sequence. They may exercise sound discretion to decide either prong first. Where it is apparent that the right was not clearly established and the constitutional question is difficult and unnecessary, the court may resolve the case on qualified immunity without deciding the merits. (Derived from Pearson v. Callahan (n.d.).)