In Harlow v. Fitzgerald (1982) 457 U.S. 800, the United States Supreme Court fashioned a strictly objective standard for evaluating a public official's claim to qualified immunity: "We therefore hold that government officials performing discretionary functions, generally are shielded from liability for civil damages insofar as their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known." ( Id. at p. 818.) The United States Supreme Court held that "government officials performing discretionary functions generally are shielded from liability for civil damages for alleged constitutional violations insofar as their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known." (Id., at p. 818.)