First Circuit
Quiles v. Kilson, 337 F.Supp.2d 224, 231 (D. Mass. 2004) (“Unlike the law with respect to strip searching, which was unclear at the time of the incident, the law relating to probable cause was clear. An objectively reasonable officer should have known that it violated the Fourth Amendment rights of the outside plaintiffs to search them if they were not originally inside the Apartment.”).