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Pearson v. Callahan
United States Supreme Court
555 U.S. 223 (2009)
Afton Callahan (plaintiff) voluntarily allowed an informant into his home to buy drugs. Once the informant bought the drugs, the informant signaled to law-enforcement officers (defendants), who entered the house without a warrant and arrested Callahan. The officers believed that they did not need a warrant because several courts had ruled that if someone gave an informant consent to enter a home, that consent extended to law-enforcement officers working with the informant. This was called the consent-once-removed doctrine. Callahan sued the officers under § 1983 for committing an unconstitutional search without a warrant. The officers claimed that they had qualified immunity and that the lawsuit should be dismissed because the consent-once-removed doctrine meant that they had not violated a clearly established right. The trial court agreed that the officers had qualified immunity. Ultimately, the United States Supreme Court granted certiorari and directed the parties to brief whether an existing rule governing qualified-immunity decisions that had been set out in Saucier v. Katz, 533 U.S. 194 (2001), should be overruled.
Rule of Law
Holding and Reasoning (Alito, J.)
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