In Malley v. Briggs (1986) 475 U.S. 335, the Supreme Court addressed "the degree of immunity accorded a defendant police officer in a damages action under 42 U.S.C. 1983 when it is alleged that the officer caused the plaintiffs to be unconstitutionally arrested by presenting a judge with a complaint and a supporting affidavit which failed to establish probable cause." (475 U.S. at p. 337.) In Malley, the Supreme Court explained that an objectively reasonable standard applies when examining police conduct in applying for a warrant. The Malley court set forth the following test: "whether a reasonably well-trained officer . . . would have known that his affidavit failed to establish probable cause and that he should not have applied for the warrant." ( Id. at p. 345.) Stated another way, the Malley court explained: "As the qualified immunity defense has evolved, it provides ample protection to all but the plainly incompetent or those who knowingly violate the law. . . . Defendants will not be immune if, on an objective basis, it is obvious that no reasonably competent officer would have concluded that a warrant should issue; but if officers of reasonable competence could disagree on this issue, immunity should be recognized." (475 U.S. at p. 341.) The court further explained: "Only where the warrant application is so lacking in indicia of probable cause as to render official belief in its existence unreasonable, ; will the shield of immunity be lost." ( Id. at p. 344-345.)