— further argue in favor of such a result. See Watson, 3 So. at 441; Firestone, 38 N.W. at 886; McMahan, 34 Vt. at-, 1861 WL 3365. On the other hand, at some point, even private citizens untrained in the niceties of probable cause must be presumed to know that a particular arrest is without justification or that a course of action in effecting an arrest is patently abusive. A proper balancing of § 1983’s protective purpose and the strong policy considerations in favor of recognizing qualified immunity, thus, suggests that the appropriate standard for gauging the objective reasonableness of a private defendant’s belief is that of the reasonable private citizen in the defendant’s position, rather than that of the reasonable law enforcement official. Cf., e.g., Rodrigues, 950 F.2d at 816 (<HOLDING>). The facts necessary to establish the
recognizing physician assistant as agent of the supervising physician holding that such a physician was a state actor under  1983 holding physician entitled to recover attorneys fees actually paid by malpractice insurer because physician was personally liable in the first instance holding similar new mexico physician license revocation procedures satisfied due process notwithstanding absence of a probable cause hearing prior to institution of proceedings against physician holding physician in action based on illegal cavity search to standard of a reasonable physician