District Of Columbia v. Wesby

Officers had probable cause to arrest partygoers based on a reasonable belief of “substantial chance of criminal activity,” established by the totality of the circumstances, and the officers making an arrest pursuant to such probable cause were entitled to qualified immunity from a civil suit.

Neighborhood residents notified police officers, Petitioners, about loud partying in a vacant house. A partier allowed police to enter. Petitioner found an improvised strip club, empty liquor bottles, marijuana, and an otherwise bare and filthy house. The Respondent partiers scattered and hid. Petitioner contacted the owner, who was absent from the scene and who told the police that the partiers were not permitted to be there. Petitioners arrested Respondents for unlawful entry. Respondents sued Petitioners for false arrest. The Court of Appeals for the District of Columbia held that Petitioners had no probable cause or qualified immunity. The Supreme Court reversed, holding that the Petitioners were reasonable in concluding from the totality of the circumstances that there was a “substantial chance of criminal activity.” The court reasoned that facts should not be evaluated in isolation, but together as a whole. The court found that Petitioners rightly took into account the Respondents unprovoked scattering, the inconsistent explanations for their presence in the house, and the admission that they had no permission to be there. Additionally, the Court held that Petitioners were entitled to qualified immunity because their conduct could not be clearly established as unlawful, which requires the constitutionality of Petitioners conduct to violate a constitutional right “beyond debate.”