The following excerpt is from Armstrong v. Asselin, No. 10-35777 (9th Cir. 2013):
"shield of immunity"24 lost only in "rare"25 circumstances, even for mistakenly issued warrants. It is the "magistrate's responsibility to determine whether the officer's allegations establish probable cause"26that is, a "fair probability" that evidence of a crime will be found.27 Qualified immunity for police officers does not even require that much, because as Ashcroft v. al-Kidd held, the shield "protects all but the plainly incompetent or those who knowingly violate the law."28
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