Carla Blake v. Don Lambert, 921 F.3d 215

Don Lambert, a Mississippi school attendance officer, filed an affidavit and obtained an arrest warrant against Carla Blake for contributing to a child's delinquency by failing to ensure school attendance.
School records listed Blake as the child S.W.’s contact and indicated S.W. lived with her; Lambert relied on those records but did not update them after Blake told him she was only the aunt and not the custodial caregiver.
Lambert’s affidavit merely identified Blake, cited the statute, and alleged the offense; it omitted Lambert’s conversations with Blake and S.W.’s parents and did not recite facts supporting probable cause.
A justice court issued the warrant; Blake was arrested, briefly jailed, strip-searched, and released on bond.
After a Department of Human Services inquiry, Lambert asked that the charge be dropped and admitted he had filed on the wrong person, but later defended the affidavit based on the school records.
Blake sued under 42 U.S.C. § 1983 alleging Fourth Amendment violations under Malley (facially deficient affidavit) and Franks (false/omitted statements); the district court denied Lambert qualified immunity and he appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Lambert violated Malley by submitting a warrant affidavit lacking probable cause	Blake: affidavit was a "barebones" recitation without supporting facts; objectively unreasonable	Lambert: relied on school records and reasonable practice; no clear precedent applying Malley to attendance officers	Court: Held Malley violation; affidavit lacked facts to show probable cause and right was clearly established
Whether Lambert is liable under Franks for false statements or omissions in the affidavit	Blake: Lambert omitted exculpatory facts and made false assertions, so Franks applies	Lambert: even if omissions/falsehoods occurred, Franks is inapplicable because affidavit was facially deficient under Malley	Court: Reversed Franks claim; a facially deficient Malley affidavit cannot support a Franks claim
Whether qualified immunity protects Lambert	Blake: qualified immunity not appropriate because the right was clearly established and conduct unreasonable	Lambert: entitled to immunity due to reliance on school records, limited training, and magistrate approval	Court: Denied qualified immunity as to Malley; granted qualified immunity as to Franks
Whether magistrate’s issuance of the warrant insulates Lambert	Blake: magistrate’s issuance does not cure a barebones affidavit	Lambert: magistrate approval should be afforded deference	Court: Magistrate deference insufficient where affidavit provided no substantial basis for probable cause

Malley v. Briggs, 475 U.S. 335 (affidavit so lacking probable cause that official belief is unreasonable)
Franks v. Delaware, 438 U.S. 154 (restricts use of knowingly false statements or deliberate omissions in warrant affidavits)
Spencer v. Staton, 489 F.3d 658 (example of a "textbook" barebones affidavit insufficient for probable cause)
Kohler v. Englade, 470 F.3d 1104 (Franks liability inapplicable when affidavit is facially deficient under Malley)
New Jersey v. T.L.O., 469 U.S. 325 (Fourth Amendment principles applied to school officials)
Anderson v. Creighton, 483 U.S. 635 (clearly established law standard for qualified immunity)
Harlow v. Fitzgerald, 457 U.S. 800 (objective standard for qualified immunity)
Messerschmidt v. Millender, 565 U.S. 535 (scope of magistrate deference in qualified immunity analysis)