Malley v. Briggs

Background

A state trooper in Rhode Island supervised a court‑authorized wiretap and interpreted intercepted phone calls as evidence that a marihuana party had been held at a couple’s home. The trooper prepared complaints and affidavits describing the calls, a judge signed arrest warrants, the couple were arrested and later released when a grand jury declined to indict. The couple sued under a federal civil‑rights law that lets people seek money damages for unconstitutional arrests.

Reasoning

The central question was how much immunity a police officer gets when he asks a judge for a warrant based on an affidavit that may not show probable cause. The Court said the officer is not absolutely immune like a prosecutor, but has only qualified immunity measured by an objective‑reasonableness test. In short, the officer can be liable only if the warrant application is so lacking in indicia of probable cause that no reasonably competent officer would have believed it.

Real world impact

The ruling means officers can be sued for damages when their warrant requests are plainly unreasonable, but ordinary mistakes that reasonable officers could make remain protected. The Court rejected the idea that the judge’s decision alone always shields the officer. The case was sent back for further proceedings to decide whether this trooper’s conduct was objectively unreasonable.

Dissents or concurrances

A concurring opinion stressed giving substantial weight to the judge’s probable‑cause finding and would have granted judgment for the officer, warning that liability might deter officers from seeking warrants.