Rivera-Guadalupe v. City of Harrisburg, 2024 U.S. App. LEXIS 32617 (3d. Cir. Court of App., December 24, 2024)(Krause, J.)
We deny officers qualified immunity for violating clearly established constitutional rights—not for their failure to read tea leaves. This past year, the Supreme Court held in Chiaverini v. City of Napoleon that “the presence of probable cause for one charge does not automatically defeat a Fourth Amendment malicious-prosecution claim alleging the absence of probable cause for another charge.” 602 U.S. 556, 561, 144 S. Ct. 1745, 219 L. Ed. 2d 262 (2024). But was that right clearly established when Detective Jacob Pierce, the Appellant in this case, arrested Appellee Jorge Rivera-Guadalupe in 2017? No, we conclude, because although we anticipated the holding of Chiaverini nearly twenty years ago in Johnson v. Knorr, 477 F.3d 75 (3d Cir. 2007), tension between Johnson and Wright v. City of Philadelphia, 409 F.3d 595 (3d Cir. 2005), continued to produce confusion within our circuit that persisted until Chiaverini. Accordingly, we will reverse the District Court’s denial of qualified immunity and remand with instruction to dismiss on that basis.
