Anderson v. Creighton
483 U.S. 635 (1987)
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Rule of Law:
A government official performing a discretionary function is entitled to qualified immunity from a civil damages suit if their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known, with the relevant right being defined in a particularized, fact-specific sense.
Facts:
- Following a bank robbery on November 11, 1983, FBI Agent Russell Anderson came to believe the suspect, Vadaain Dixon, might be located at the Creighton family's home.
- Anderson, along with other state and federal law enforcement officers, went to the Creighton residence.
- The officers conducted a search of the Creighton family's home without a search warrant.
- The suspect, Vadaain Dixon, was not present in the home.
Procedural Posture:
- The Creightons sued FBI Agent Anderson in Minnesota state court, claiming money damages for a violation of their Fourth Amendment rights.
- Anderson removed the lawsuit to the U.S. District Court for the District of Minnesota.
- Anderson filed a motion for summary judgment, asserting he was protected by qualified immunity.
- The District Court granted summary judgment for Anderson, holding that the search was lawful because it was supported by probable cause and exigent circumstances.
- The Creightons, as appellants, appealed to the U.S. Court of Appeals for the Eighth Circuit.
- The Eighth Circuit, with Anderson as appellee, reversed the District Court's grant of summary judgment.
- The Court of Appeals held that unresolved factual disputes made it impossible to rule that the search was lawful and that Anderson was not entitled to qualified immunity because the right to be free from such a search was 'clearly established.'
- Anderson petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.
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Issue:
Is a federal law enforcement officer who conducts a warrantless search that violates the Fourth Amendment entitled to qualified immunity from money damages if a reasonable officer in the same situation could have believed the search was lawful?
Opinions:
Majority - Justice Scalia
Yes. An officer is entitled to qualified immunity if a reasonable officer could have believed the search was lawful under the circumstances, even if it was later found to be unconstitutional. The doctrine of qualified immunity shields government officials from civil liability as long as their actions are objectively legally reasonable in light of the legal rules that were clearly established at the time. The Court of Appeals erred by defining the 'clearly established' right at too high a level of generality (the right to be free from warrantless searches without probable cause and exigent circumstances). The proper inquiry must be more particularized: whether the unlawfulness of the specific actions taken by the officer would have been apparent to a reasonable officer in that situation. Therefore, Anderson is entitled to summary judgment if he can establish that a reasonable officer, possessing the information he had, could have believed the warrantless search was supported by probable cause and exigent circumstances.
Dissenting - Justice Stevens
No. The majority creates a 'double standard of reasonableness' that improperly insulates police from accountability and diminishes the protections of the Fourth Amendment. The constitutional standard of reasonableness for a search already incorporates leeway for officer mistakes. Creating a second, more lenient standard of reasonableness for immunity purposes allows an officer to act 'unreasonably' under the Fourth Amendment but be shielded from liability because they 'reasonably' believed their unreasonable conduct was lawful. The Harlow qualified immunity standard, designed for high-level executive officials making policy decisions, is inappropriate for law enforcement officers in the field. The proper approach would be to deny immunity at the summary judgment stage when the law is clear, as it was here, and allow the officer to raise a good-faith defense at trial based on the facts.
Analysis:
This decision significantly strengthened the qualified immunity defense by requiring a highly specific and particularized inquiry into whether a right was 'clearly established.' It shifts the focus from abstract constitutional principles to the concrete, factual context of the official's actions. This makes it substantially more difficult for plaintiffs to overcome a qualified immunity defense, as they must often find a prior case with nearly identical facts to show the law was clearly established. The ruling solidified qualified immunity as a powerful barrier to civil rights litigation against law enforcement, shaping decades of subsequent jurisprudence in this area.
