ANDERSON V. CREIGHTON
483 U.S. 635 (1987)
NATURE OF THE CASE: This was an appeal from a reversal of a lower court holding by the
Court of Appeals related to the issues of qualified immunity and alleged violations of the
Fourth Amendment and entitlement to summary judgment for the officer holding the qualified
immunity.
FACTS: Anderson (D) is an agent of the Federal Bureau of Investigation. D and other state
and federal law enforcement officers conducted a warrantless search of the home of the
Creighton family (P). The search was conducted because D believed that Vadaain Dixon, a man
suspected of a bank robbery committed earlier that day, might be found there. He was not. Ps
filed suit against D in a Minnesota state court, asserting among other things a claim for
money damages under the Fourth Amendment. After removing the suit to Federal District Court,
D filed a motion to dismiss or for summary judgment, arguing that the Bivens claim was
barred by D's qualified immunity from civil damages liability. The District Court granted
summary judgment on the ground that the search was lawful, holding that the undisputed facts
revealed that D had had probable cause to search the P's home and that his failure to obtain
a warrant was justified by the presence of exigent circumstances. Ps appealed to the Court
of Appeals for the Eighth Circuit, which reversed. The Court of Appeals held that the issue
of the lawfulness of the search could not properly be decided on summary judgment, because
unresolved factual disputes made it impossible to determine as a matter of law that the
warrantless search had been supported by probable cause and exigent circumstances. The Court
of Appeals also held that D was not entitled to summary judgment on qualified immunity
grounds, since the right D was alleged to have violated - the right of persons to be
protected from warrantless searches of their home unless the searching officers have
probable cause and there are exigent circumstances - was clearly established. The Supreme
Court granted certiorari.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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