In Renk v. City of Pittsburgh, 537 Pa. 68, 641 A.2d 289 (1994), the Supreme Court set forth that "the purpose of the indemnification provisions '...is to permit local agency employees to perform their "official duties" without fear of personal liability, whether pursuant to state or federal law, so long as the conduct is performed during the course of their employment.'" 537 Pa. at 73, 641 A.2d at 292. In Renk, a police officer was found liable in a civil suit for assault and battery, paid the judgment and then filed suit for indemnification under the Political Tort Claims Act from the municipality. The Supreme Court held that a police officer may be so indemnified absent a judicial determination that he was found guilty of willful misconduct. In Renk, it was unclear whether the jury in the federal action found that the police officer intentionally used excessive force to make the arrest or only if he intentionally used force and also, it was not clear whether the officer made the arrest knowing he lacked probable cause or only that he lacked probable cause to make the arrest.