Junkert v. Massey

Dist. Ct. did not err in denying plaintiff's motion for judgment notwithstanding jury's verdict in favor of defendant-Sheriff in section 1983 action alleging that defendant's search of plaintiff's law office and home violated her 4th Amendment rights even though subject search was obtained after issuance of search warrant. Although affidavit supporting issuance of warrant lacked sufficient probable cause regarding informant's claim that plaintiff possessed stolen laptop computers, defendant was still entitled to qualified immunity where: (1) no prior case had ever held that similar affidavit lacked probable cause under similar circumstances; and (2) certain facts in affidavit partially corroborated informant's claim that plaintiff had obtained laptops from alleged drug-dealing client so as to negate any claim that affidavit was so deficient that any reasonably-trained officer would have known that probable cause was lacking.