Amesbury v. Manning, 1:24-cv-00257

Brian Amesbury sued various officials from the Pawtucket Fire Department and the Rhode Island State Fire Marshal’s Office under 42 U.S.C. § 1983 for two searches of his rental unit at 110 Tweed Street, Pawtucket, in June and August 2021.
He claimed the June search was warrantless, retaliatory, and unreasonable, and that the August search was invalid because the administrative warrant cited "determining the origin and cause of the fire" when no fire had occurred.
The defendants included city fire officials, the mayor of Pawtucket, and several state fire marshal investigators and supervisors, each sued in either individual or official capacities.
Amesbury argued the searches infringed his Fourth and Fourteenth Amendment rights, and brought additional claims of retaliation for protected speech.
Defendants moved to dismiss all claims, chiefly asserting qualified immunity applies based on their statutory duties to enforce fire safety laws.
The court decided the motion to dismiss, focusing especially on the qualified immunity defense and the facial validity of the warrant.

Issue	Plaintiff's Argument	Defendant's Argument	Held
June 2021 warrantless search - Fourth Amendment	Search was warrantless and retaliatory	Statute allows inspection for fire code compliance	Dismissed; statute authorized, qualified immunity
June search as retaliation	Search was motivated by protected fire code report	Legitimate, statutorily allowed reasons for entry	Dismissed; no causal link or temporal proximity
August 2021 warrant’s validity	Warrant invalid—referenced non-existent fire	Administrative warrant was facially valid	Dismissed; officers reasonably relied on warrant
Supervisor liability on both searches	Supervisors knew/should have known of violations	Subordinates’ actions were not unconstitutional	Dismissed; no underlying constitutional violation

Pearson v. Callahan, 555 U.S. 223 (qualified immunity shields officials unless law is clearly established)
Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard for plausible claims)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading standard for plausible claims)
Malley v. Briggs, 475 U.S. 335 (qualified immunity does not protect plainly incompetent officials)
Anderson v. Creighton, 483 U.S. 635 (qualified immunity requires violation of clearly established right)
Camara v. Mun. Court of San Francisco, 387 U.S. 523 (administrative search warrants for inspections)
New Jersey v. T.L.O., 469 U.S. 325 (balancing test for reasonableness of searches)
Riley v. California, 573 U.S. 373 (balancing privacy and governmental interests in search context)