Akeem Washington v. Shannon Rivera, 939 F.3d 1239

Washington received a speeding ticket, appeared before Judge Carney, and told the court he would pay the fine that day; the judge said paying by a deadline would avoid probation and instructed the clerk to notify probation on payment.
Washington immediately paid the fine at the clerk’s office; the clerk updated records and called probation staff, but probation (including Rivera) was not notified.
Months later a document was filed sentencing Washington to probation; Rivera (a Bryan County probation officer) signed an arrest warrant stating Washington had not paid, which Judge Carney later signed; Rivera did not verify payment with the clerk or others before signing.
Washington was arrested pursuant to the warrant, detained, then released after Rivera confirmed his payment; he lost his job as a result and sued Rivera under 42 U.S.C. § 1983 (Fourth Amendment) and state law.
Rivera moved for judgment on the pleadings asserting quasi-judicial (absolute) immunity, qualified immunity, and Georgia Tort Claims Act (GTCA) immunity; the district court denied relief and Rivera appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Quasi-judicial immunity (absolute)	Rivera’s warrant application is not judicial in nature and she is not entitled to absolute immunity	Rivera, as a probation officer preparing a violator warrant, is performing an adjudicatory/judicial function and should have absolute immunity	Court: Not entitled to quasi-judicial immunity; applying for an arrest warrant is investigative/executive, not sufficiently judicial (Malley controlling)
Qualified immunity (Fourth Amendment)	Rivera knowingly ignored or failed to investigate exculpatory information and thus violated clearly established Fourth Amendment rights	Rivera reasonably relied on clerk/probation procedures and could have believed her conduct lawful; no clearly established law required further inquiry here	Court: Rivera entitled to qualified immunity because existing precedent did not clearly establish that her conduct violated the Fourth Amendment
GTCA / State statutory immunity	Rivera acted as a state actor (probation officer acting for the court) and thus is covered by the Georgia Tort Claims Act	Rivera is employed by the county sheriff’s office and acted on behalf of the county, so GTCA (which excludes counties) does not apply	Court: Rivera not entitled to GTCA immunity; as a county sheriff’s employee acting in an investigative/administrative role she was not acting on behalf of the State

Malley v. Briggs, 475 U.S. 335 (1986) (applying for an arrest warrant is not sufficiently judicial to warrant absolute quasi-judicial immunity)
Kingsland v. City of Miami, 382 F.3d 1220 (11th Cir. 2004) (officers who ignore or fabricate exculpatory evidence may not receive qualified immunity)
Tillman v. Coley, 886 F.2d 317 (11th Cir. 1989) (officer must investigate where serious doubts about identity or guilt exist)
Post v. City of Fort Lauderdale, 7 F.3d 1552 (11th Cir. 1993) (reasonable but mistaken investigatory errors can support arguable probable cause and qualified immunity)
Imbler v. Pachtman, 424 U.S. 409 (1976) (prosecutorial immunity principles distinguishing truly judicial functions)
Harlow v. Fitzgerald, 457 U.S. 800 (1982) (qualified immunity framework)
Anderson v. Creighton, 483 U.S. 635 (1987) (standard for when a right is "clearly established")
Hunter v. Bryant, 502 U.S. 224 (1991) (reasonable but mistaken conclusions of probable cause are protected by qualified immunity)