In United States v. Brinkley, the The Fourth Circuit held that officers, armed with an arrest warrant, lacked probable cause to enter an apartment where they had reason to believe the defendant resided. In its decision, the court noted that the courts of appeal split on the quantum of proof required for an officer to show that he or she had reasonable belief to enter a residence with an arrest warrant.
In Barrett v. PAE Government Services, the Fourth Circuit affirmed the district court’s grant of summary judgment in favor the defendants—two Arlington County, Virginia police officers and one of the County’s mental health examiners—after the defendants were sued under 42 U.S.C. § 1983.
In Estate of Jones v. City of Martinsburg, the Fourth Circuit held that the City of Martinsburg could not be held liable for a single incident of excessive force, by its police officers, that led to a man’s death.