What is the test for qualified immunity for a police officer who makes a warrantless arrest?

"The doctrine of qualified immunity shields police officers acting in their official capacity from suits for damages under 42 U.S.C. 1983, unless their actions violate clearly-established rights of which an objectively reasonable official would have known." Thomas v. Roach, 165 F.3d 137, 142 (2d Cir.1999).

When a plaintiff alleges an arrest without probable cause, an arresting officer may assert the defense of qualified immunity if "either (a) it was objectively reasonable for the officer to believe that probable cause existed, or (b) officers of reasonable competence could disagree on whether the probable cause test was met." Golino v. City of New Haven, 950 F.2d 864, 870 (2d Cir.1991). Thus, a police officer who makes a warrantless arrest is entitled to summary judgment on the ground of qualified immunity only "if a jury, viewing all facts in the light most favorable to the plaintiff, could conclude that officers of reasonable competence could disagree on the legality of the defendant's actions." Cerrone v. Brown, 246

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F.3d 194, 202 (2d Cir.2001) (internal quotation omitted).