Wilson v. Layne

In Wilson v. Layne, 526 U.S. 603 (1999), the Court found that the right was not sufficiently clearly established to warrant finding the individual officers liable in damages. The Wilson Court noted that "what `clearly established' means in this context depends largely upon the level of generality at which the relevant legal rule is to be identified." Wilson, 526 U.S. at 614. The Court stated: It could plausibly be asserted that any violation of the Fourth Amendment is "clearly established," since it is clearly established that the protections of the Fourth Amendment apply to the actions of police.... However, the right allegedly violated must be defined at the appropriate level of specificity before a court can determine if it was clearly established. In this case, the appropriate question is the objective inquiry of whether a reasonable officer could have believed that bringing members of the media into a home during the execution of an arrest warrant was lawful, in light of clearly established law.... Id. at 615. The Court then proceeded to answer the question it posed. "First," it said, "the constitutional question presented by this case is by no means open and shut.... Accurate media coverage of police activities serves an important public purpose, and it is not obvious from the general principles of the Fourth Amendment that the conduct of the officers in this case violated the Amendment." Id. at 615-16. Second, the Court cited the absence of any decisions that were directly on point. Third, it pointed out that the officers had relied on a policy of the Marshal's Service that "explicitly contemplated that media who engaged in ride-alongs might enter private homes," and that where the state of the law was undeveloped, it was not unreasonable for the officers to rely on a formal policy of their department. Id. at 617. As a result, the Court concluded that it would not have been unreasonable for an officer to have believed, in 1992, that the ride-along was lawful. See id. at 617-18.