In Kirk v. City of Newark, 109 N.J. 173, 536 A.2d 229 (1988), New Jersey adopted Harlow's "objective reasonableness" standard for determining whether law enforcement officials are entitled to the qualified immunity defense in 1983 actions. Kirk held that such an official can defend a 1983 claim by demonstrating either that he or she acted with probable cause, or that a reasonable law enforcement officer could have believed there was probable cause. Id. at 184, 536 A.2d 229. Kirk also recognized that the United States Supreme Court "has interpreted Section 1983 to limit the rights of plaintiffs and to encourage disposition of the actions as a matter of law, at least when these actions arise out of an alleged unlawful arrest, search, or seizure by a law enforcement officer." Id. at 179, 536 A.2d 229.