art. III, § 2, cl. 1.)). A ruling in favor of Donaghy would create a perverse incentive that would allow the government to avoid liability by conceding an issue for decades and subsequently arguing that the law was not clearly established on that issue because there were no cases directly on point. As to Donaghy’s latter point, while a detainer is distinct from an arrest, it nevertheless results in the detention of an individual. See 8 C.F.R. § 287.7. Morales alleges that after her criminal custody had terminated, she was detained for 24 additional hours based solely on the detainer issued by Donaghy. Because Morales was kept in custody for a new purpose after she was entitled to release, she was subjected to a new seizure for Fourth Amendment purposes — one tha , 228 (1st Cir.1990) (<HOLDING>). The natural consequence of Donaghy issuing
holding that an officer whose request for a warrant allegedly caused an unconstitutional arrest can be held liable for the arrest where the warrant application is so lacking in indicia of probable cause as to render official belief in its existence unreasonable holding that an officer could be held liable for failing to intervene in preventing an unlawful strip search holding invalid warrant did not create probable cause for arrest holding that an officer who knowingly processed an invalid warrant could be held liable for the subsequent unlawful arrest holding a defendants response to even an invalid arrest  may constitute independent grounds for arrest