Pierson v. Callahan

Supreme Court of the United States · 2009 · Federal Courts

Federal CourtsQualified ImmunitySection 1983Fourth Amendmentqualified immunitySaucierclearly established lawSection 1983

Facts

A confidential informant told a narcotics task force that respondent planned to sell him methamphetamine. After being searched, wired, and given a marked bill, the informant entered respondent's trailer with consent, bought methamphetamine, and gave a prearranged arrest signal. Officers then entered through the porch door without a warrant, encountered respondent and others, saw respondent drop a bag later determined to contain methamphetamine, and conducted a protective sweep that uncovered more drugs and related evidence. In the later § 1983 suit, the dispute centered on whether the officers' warrantless entry violated clearly established law.

Issue

Whether courts must always follow Saucier's mandatory sequence by deciding first whether the facts show a constitutional violation before deciding whether the right was clearly established. Whether, under the law existing in 2002, the officers were entitled to qualified immunity for the warrantless entry into respondent's home.

Rule

In qualified immunity cases, courts are no longer required to follow Saucier's rigid two-step sequence in every case; instead, lower courts may exercise sound discretion in deciding which prong of the qualified-immunity analysis to address first. An officer is entitled to qualified immunity unless the officer's conduct violated a constitutional right that was clearly established at the time, judged by the objective legal reasonableness of the action in light of then-existing legal rules.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Denver, Maya Torres sued two city housing inspectors under § 1983 for damages, alleging that their inspection of her apartment violated the Fourth Amendment. The district judge concluded that, at the time of the inspection, no precedent had clearly established that the challenged inspection method was unconstitutional, but the constitutional issue itself was novel and difficult.

How should the court proceed on the qualified-immunity issue?

Explanation. Lower courts are no longer required to follow a rigid order in qualified-immunity cases. They may exercise sound discretion to decide either prong first. Where the constitutional question is difficult but it is clear that the law was not clearly established at the time, the court may resolve the case on that ground alone and avoid unnecessarily deciding the constitutional issue.