Blake v. Lambert, No. 18-60176 (5th Cir. 2019)
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After defendant, a Mississippi school attendance officer, swore an arrest warrant affidavit against plaintiff for failure to ensure a child attended school, plaintiff filed suit alleging that defendant violated her Fourth Amendment rights because the affidavit lacked probable cause under Malley v. Briggs and was untruthful under Franks v. Delaware. The district court denied defendant's motion for summary judgment based on qualified immunity.
The Fifth Circuit affirmed as to the Malley claim and held that the affidavit lacked any facts to establish probable cause. However, the court reversed as to the Franks claim because it was incompatible with a Malley theory. The court held that a plaintiff cannot hold an officer liable under Franks for intentionally omitting important exculpatory information from a warrant affidavit when the officer has also committed a Malley violation by presenting a facially deficient warrant affidavit to the issuing judge.
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