accommodating these often opposing interests. Requiring more would unduly hamper law enforcement. To allow less would be to leave law-abiding citizens at the mercy of the officers’ whim or caprice. Id. (quotation omitted). Thus, probable cause represents an accommodation between the “opposing interests” of police officers and criminal suspects, id., the same interests that we must balance here. Rather than require something beyond probable cause — the “reasonable investigation” Lahm demands — we have long held that probable cause is sufficient grounds for an arrest. We reached a similar decision in a different context when we determined that municipal police officers are shielded from common law tort claims by official immunity. See Everitt v. Gen. Elec. Co., 156 N.H. 202, 219 (2007) (<HOLDING>). We noted in Everitt that the doctrine of
holding that municipal police officers are immune from personal liability for decisions acts or omissions that are 1 made within the scope of their official duties while in the course of their employment 2 discretionary rather than ministerial and 3 not made in a wanton or reckless manner holding that police officers were not entitled to immunity under the itca law enforcement immunity provision where the officers violated their statutory duty to drive with due regard for the safety of all individuals while acting within the scope of their employment holding that notice statute applies to both municipal entities and employees of municipal entities acting within the scope of their employment holding that statement is admission by partyopponent if made by partys agent or servant concerning matter within course and scope of the agency or employment and made during existence of agency or employment relationship holding that a state official can be held individually hable under  1983 for acts taken within the scope of his or her official duties