law. That notion is plainly contradicted by Harlow, where the Court completely reformulated qualified immunity along principles not at all embodied in the common law ... 483 U.S. at 644-45, 107 S.Ct. at 3041-42 (citations omitted) (footnote omitted); see also Wyatt, 504 U.S. at 166, 112 S.Ct. at 1832 (affirming this characterization of Harlow). The distinction between Tower and Anderson perhaps lies in the fact that in Tower, the Court found no common-law support for the immunity in question, while in Anderson, it did, albeit not for the precise factual scenario there in question. Compare Tower, 467 U.S. at 922, 104 S.Ct. at 2825 (finding that common law did not shield defense lawyers from tort liability for intentional misconduct), with Anderson, 483 U.S. at 645, 107 S.Ct. at 3042 (<HOLDING>). Thus, in cases such as this, where there is
recognizing a direct liabilitymanagement theory and explaining that  under these circumstances strict adherence to the general rule that liability for bad faith breach may be imposed only against a party to an insurance contract would permit farmers to shield itself from liability through the device of a management company  holding that one of the principal purposes of the qualified immunity doctrine is to shield officers not only from liability but also from defending against a lawsuit holding that township supervisors absolute immunity from suit because of their positions as high public officials may not be used to shield the township itself from liability holding that qualified immunity is designed to shield from liability all but the plainly incompetent or those who knowingly violate the law  holding that common law would shield officers from liability if fugitive was present in thirdpartys home