Can a police department be found to have qualified immunity from prosecution for using excessive force against a photographer?

MultiRegion, United States of America

The following excerpt is from Carson v. County of Stanislaus, 1:10-cv-02133-OWW-SMS (E.D. Cal. 2011):

accord Adkins v. Guam Police Dep't, 2010 U.S. Dist. LEXIS 87353 *33-35 (D. Guam 2010) (granting qualified immunity because no clearly established federal law holds that restricting ability to photograph violates First Amendment).

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