Carroll v. Carman

Government officials retain qualified immunity unless “existing precedent [ . . . ] placed the statutory or constitutional question beyond debate.”

Petitioners, Pennsylvania State Troopers, responded to a report that a car thief had fled to Respondents’ residence. Petitioners parked in a gravel area facing the side of Respondent’s property. Petitioners approached Respondents’ back door and knocked. Respondent refused to give his name, and refused to answer when Petitioners asked if the car thief was inside. Then Respondent turned away from Petitioners, and Petitioner grabbed Respondent’s arm to keep him from possibly reaching for a weapon. Respondent then lost his balance and fell. Respondent’s wife then came outside, identified herself and consented to a search. Petitioners did not find the car thief, and left.

Respondents filed suit under 42 USC 1983, alleging that their Fourth Amendment rights were violated when Petitioners went to their back door instead of the front. The district court denied Respondents’ motion for judgement as a matter of law, and the jury returned a verdict in favor of Petitioner. Respondents appealed, and the United States Court of Appeals for the Third Circuit reversed the district court decision, holding that the “knock and talk” exception to the warrant requirement requires officers to “begin their encounter at the front door, where they have implied invitation to go.” Petitioners appealed, and the United States Supreme Court granted certiorari to clearly establish conduct protected by qualified immunity. The Court reversed and remanded the Third Circuit decision, holding that "whether or not the constitutional rule applied by the court below was correct [ . . . ] was not ‘beyond debate.’”