Qualified Immunity: Where Constitutional Law Meets Public Safety

In this compelling episode of Consider the Constitution, host Dr. Katie Crawford-Lackey explores one of the most contentious intersections of constitutional law and public policy with Professor Hank Chambers from the University of Richmond Law School. Together, they unpack the complex doctrine of qualified immunity and its relationship to police discretion—topics that have become central to national debates about policing, accountability, and civil rights.

Professor Chambers breaks down what qualified immunity actually means, explaining how it allows law enforcement officers to avoid liability in certain situations, even when constitutional violations may have occurred. 

Professor Chambers offers a nuanced perspective on why some view qualified immunity as necessary protection for officers doing difficult work, while others see it as a barrier to accountability.

Transcript

Katie Crawford-Lackey: 0:00

Thank you very much. Hello and welcome back to Consider the Constitution. I'm your host, Dr. Katie Crawford Lackey with James Madison's Montpelier. Today, we're digging into one of the most complex and controversial intersections of constitutional law and public policy. Qualified immunity and police discretion. These legal doctrines have become central to national debates about policing, accountability, and civil rights. But they're also often misunderstood. So what exactly is qualified immunity and why does it matter? How do we balance an officer's need to make quick decisions with the public's right to constitutional protections? These are some of the questions we'll be addressing today. With the help of our expert guest, Professor Hank Chambers, the Austin E. Owen Research Scholar and Professor of Law at the University of Richmond Law School. An expert in constitutional law, Professor Chambers teaches and writes in the areas of constitutional law, criminal law, law and religion, and employment discrimination. He's published dozens and dozens of academic articles, book chapters and news articles. He also frequently lectures on constitutional law through the We the People program, which provides civic education instruction to school teachers and the public. He has also lectured here at James Madison's Montpelier. So, Professor Chambers, thank you so much for joining us today and bringing your insight into the ways our legal system navigates this tension between discretion and accountability. It's great to have you here.

Henry Chambers, Jr.: 2:24

It's great to see you, Katie.

Katie Crawford-Lackey: 2:26

So let's begin by setting the foundation first. Professor Chambers, can you tell us what is qualified immunity and how does it work within this broader legal framework?

Henry Chambers, Jr.: 2:38

Sure, sure. Qualified immunity as a definition, broadly speaking, allows for folks who have engaged in what we would think of as wrongdoing to avoid liability. Now, There are some who would say that's an unfair way of thinking about it. And there's some who would say, well, that's an overly fair way of thinking about it. But let me give a sense of what's what. You don't need immunity unless there's been wrongdoing. The point to immunity is I would otherwise be responsible and I'm being deemed not responsible because of some other societal reason or justification, right? So if we start with that as a context, that can allow us to get into the idea of qualified immunity when people are not going to be held responsible for wrongdoing and when they are. In the broader context, what we have to think about, particularly when we think about police officers, oftentimes it's law enforcement folks, even though qualified immunity can apply to other folks as well. But let's keep it to police officers and law enforcement. The key is that law enforcement has to interact with the public. And oftentimes they're interacting with the public in a physical way. So that's one of the reasons why you're going to find the need for immunity in circumstances with law enforcement, because quite literally they're enforcing the law. And as a consequence, they're just going to come in contact with people more often. So part of the question is, given the contact in which they're going to come into contact with people, How do you think about the notion of when you're going to be liable, when you're going to be responsible, when that conduct gets out of hand? And that's a part of what's going on with qualified immunity. The notion is not that you don't want officers to be responsible for their actions, but you want them to be responsible in a way that's appropriate as opposed to a way that just says there was wrongdoing, therefore officers are going to be liable.

Katie Crawford-Lackey: 4:44

And where does the concept of police discretion come in? What does it mean and how does that play out?

Henry Chambers, Jr.: 4:53

Sure. When we think about police discretion, that gets at the notion of what do I need to do in this circumstance in order to engage in proper law enforcement behavior? So there will always be an opportunity for a police officer to say, well, I'm not going to do anything. versus I'm going to do something versus I'm going to do too much. So the question of what you're allowed to do, how close you're allowed to get to the line without going over the line, or whether you're allowed to go a little over the line because in certain circumstances, what you've got to do is think in a split second moment, what do I do? That can be a way of thinking about qualified immunity and saying the point to qualified immunity is to allow folks to go just over the line every now and again and also be protected from the immediate liability that may come from that. There are others who would argue Well, yes, you've described qualified immunity correctly, but that's a problem because you never want people to be able to go over the line and avoid liability. What you want is for the notion of civil liability to get people to not go over the line at all. And it's when you give them a doctrine that allows them to go over the line somewhat that that's where the problem arises. And I don't disagree with either piece of the puzzle. Part of the question becomes, where is the line itself?

Katie Crawford-Lackey: 6:18

And how is that line determined? How can we, whether it be citizens, police officers themselves, how do we know where that line is?

Henry Chambers, Jr.: 6:29

Yes. As a law professor, the question is, well, it depends. One of the problems that you run into is that the line arguably moves a little bit or can move a fair amount over time, or it's a line that we think of as relating to reasonableness. The Supreme Court will deal with issues of what qualifies as an unlawful search or an unlawful seizure. And sometimes that gets down to the question of reasonableness. By the same token, when we think about Fourth Amendment issues, we think about either a notion of reasonable ability to articulate the problem or reasonable suspicion versus probable cause. Neither of those terms is crystal clear. But they oftentimes are the gateway to allow police to use force in certain circumstances in order to deal with a situation. So exactly where the line is, that's part of the problem, is if we had an easy way to figure out exactly where the line is or whether a police officer's conduct was precisely correct, then some of these issues might go away. Part of the problem is what qualifies as reasonable and what qualifies as unreasonable. When you think about the concept of excessive force, for example, the term excessive force necessarily makes us think that there's something called non-excessive force. And there is non-excessive force in some circumstances. That is to say, if a law enforcement officer has the right to arrest someone and has the right to use force to do so, then some force will be perfectly acceptable. Right. It's only when the force becomes excessive that we then move toward excessive force, at which point we can then say, okay, you've crossed the line. But where exactly that line is, is going to depend on the specific circumstances. And that gets at the notion that there isn't a crystal clear line. And the lack of a crystal clear line is part of the problem.

Katie Crawford-Lackey: 8:28

And so in context to the Constitution, when we think about, you know, you referenced the Fourth Amendment, officers... being aware of and respecting these rights, but then also, as you said, need to arrest somebody if somebody possibly broke the law. Can you give us an example or a real-world situation where this question comes into play of qualified immunity and police discretion?

Henry Chambers, Jr.: 8:53

Sure. There can be situations where that occurs. There actually is a case that I wrote about a few years back. It's not a seminal case in any way, and that can be a real positive. Sometimes a seminal case is get in the way in part because they are so seminal. Well, this is a case called Jameson versus McClendon out of Mississippi. This is a federal case. And the basic notion, this was the facts basically from the opinion itself. In fact, I'll go ahead and read a summary of what Judge Carlton Reeves wrote in the opinion. It says, As he made his way home to South Carolina from a vacation in Arizona, Jameson was pulled over and subjected to 110 minutes of an armed police officer badgering him, pressuring him, lying to him, and then searching his car top to bottom for drugs. Nothing was found. Jameson isn't a drug courier, he's a welder. Unsatisfied, the officer then brought out a canine to sniff the car. The dog found nothing, so nearly two hours after it started, the officer left Jameson by the side of the road to put his car back together. Now, we might well say, well, that's a clear violation. And the notion is, well, it depends. What it might depend on, and this case was an issue, is whether or not there was consent to search. And you may say, well, consent is obvious. Either you give it or you don't. Well, here's the problem. What happens when consent is coerced? The question of whether there was sufficient coercion to make it non-consensual is a real issue. So now we're in a gray area. Well, in this particular case, Judge Reeves said, look, as much as I would like to not dismiss the case, I'm required to because of qualified immunity. Given the circumstances that existed, given the fact that the officer did not violate a clearly established law or practice based on the facts involved in the case, got to dismiss the case. It's a fascinating read. The opinion as a whole is a fascinating read because it gets at the notion of where's the line and what do you do? And let's be clear, Officer McClendon was not found liable for anything. The point to qualified immunity in part is to say, even if this turned out to be a problem, the facts don't provide the basis for us to say that there wouldn't be qualified immunity. So part of what's being asked is, is this inside of the realm of what would be covered by qualified immunity? And if the answer is yes, then we get rid of the case before we have an adjudication. So it's a really interesting way of applying the notion of qualified immunity.

Katie Crawford-Lackey: 11:35

So the officer basically wasn't charged with anything. The judge found he was within his purview as an officer.

Henry Chambers, Jr.: 11:43

Let's say what the judge found was, we're not going to look any farther because even if this was an improper stop or an improper search, the way he got to searching was inside of the realm of what would be covered by qualified immunity. So we don't have to look specifically at the issue. That's the piece of the puzzle. And qualified immunity is about saying, let's go ahead and take this off of the docket before we go too far down the path. So oftentimes before there's been discovery, et cetera. The reason why I laid out what Judge Reeves wrote in the opinion was, it's pretty clear from what Judge Reeves wrote that he thought there was a Fourth Amendment violation. What he couldn't do is say, Given the facts of this case and given how things supposedly played out in the complaint that the plaintiff filed, I can't say that this would have been an appropriate case for us to avoid qualified immunity. Therefore, it's covered by qualified immunity. Therefore, we're not taking the case any farther. That's the danger. And that's where the fuzzy line is. And one of the things that Judge Reese is saying is it's pretty darn clear that this could have been over the line. That is, it could clearly have been a violation of the Fourth Amendment. What I can't say is that it was a violation of the Fourth Amendment that was so far over the line that qualified immunity would not cover it. So part of the standard for qualified immunity is that the officer's conduct has to violate a clearly established law or practice. And what that tends to mean is, do we have a court case of which the officer should have been aware that that would have told the officer, what I'm doing is unlawful. And that's the piece of the puzzle. So there actually is a great quote from the Supreme Court case, Mullenix versus Luna, 2015 case. And it says, quote, put simply, qualified immunity protects all but the plainly incompetent or those who knowingly violate the law. That's the notion behind the standard. That is not to say that lots of officers are plainly incompetent or knowingly violate the law. It's just to say that that's the standard that at least the Supreme Court has suggested seems to exist with respect to qualified immunity. There are still times when folks are in fact plainly incompetent. There are times when folks clearly do knowingly violate the law. Under those circumstances, qualified immunity does not help the officer.

Katie Crawford-Lackey: 14:24

Interesting. So if an officer is deemed incompetent or knowingly is doing something illegal, that's when they would not be covered by qualified immunity.

Henry Chambers, Jr.: 14:36

Absolutely. Because under those circumstances, it's not a serious argument. They're also not making a real serious argument that I was trying to follow the law. Think of it this way. There are some mistakes that we make that are just mistakes. Somebody makes a mistake. We say, okay, you made a mistake. Mistakes don't always trigger liability. Indeed, if we look at this from a tort law perspective, and I realize we're talking about constitutional law, but that's okay. There are classes called constitutional torts. So every now and again, you can get there. But we think about tort law and we think about the idea of negligence. The notion about negligence is that you were more than just a little careless. You were more careless than the normal person would be. So if you were careless in the way that everyone's careless, that's not necessarily going to trigger negligence. liability. That's going to trigger a saying, oh, for crying out loud, don't be goofy. So there are times when you can make mistakes and even times when you can make mistakes and might cause damage that won't necessarily trigger legal liability. If you think about qualified immunity kind of in that way, that's where we are. The problem, of course, is that when a law enforcement officer makes that mistake, it's going to tend to be in a context where it qualifies as a constitutional violation. Because the law enforcement officer is always working with the power of the state behind his or her actions. So it's literally the state that is making a mistake. And the mistake that the state makes will almost always affect our constitutional rights.

Katie Crawford-Lackey: 16:11

Professor Chambers, I can see how your point earlier about some people say this is totally fair, qualified immunity, and then others saying, no, this is not fair. who is determining if qualified immunity should be given in terms of, for example, in the case that you were describing, it's the judge making that determination. Is that typically what happens?

Henry Chambers, Jr.: 16:38

Yep. It has to be that the judge is trying to determine whether whether the officer's behavior has crossed the line. And again, not cross the line between unconstitutional and constitutional, but cross a line between so unconstitutional that qualified immunity won't save the officer's actions. That's got to be a judge who's going to end up doing that. Now, again, oftentimes that decision is made before we have a trial or anything along those lines. We're doing it what we call on the paper. So the question becomes, well, okay, if we believe everything the plaintiff says, might there be liability that is not covered by qualified immunity? That's really the decision that's being made. And that's a judge decision that has to be made in the context of a case, not necessarily a trial, but in the context of a case.

Katie Crawford-Lackey: 17:27

Why do you think this topic has become such a big focal point, at least among not just plaintiffs, folks in the field of law enforcement or the legal field, but amongst the public?

Henry Chambers, Jr.: 17:39

Yeah, a couple pieces of the puzzle. One is body-worn cameras. We just see a lot more police behavior now than we saw before. And some people are shocked. And some of the things that are done don't look good. Now, some of the things that are done that don't look good, police officers would tell you, That's just good police work. So when you think about certain behaviors that require force, let's assume that we have a civilian who is not happy with what police officer is doing, but let's assume the police officer has a right to do it, either detain or arrest. At some point, the officer may well need to use force in order to gain compliance. Some amount of force is acceptable force. Some amount of force is excessive force. You look at the video and I imagine that if you have a set of law enforcement officers, they will find much more force to be acceptable. If you find a group of civilians, they will find much less force to be acceptable. And that's a part of what's going on here. So we see it on video. One, and number two, because we see it on video, we're more likely to take the citizens slash victims position into account in part because many of us would see us as being the victim as opposed to being law enforcement. So keep that piece in mind and just think about some of the videos that we have seen in the last 10, 15 years and how many of them are ones that people have said, well, There's an argument that this is okay. So I'm not going to make the argument, but there are people who argue that the George Floyd situation was not criminal, not a problem. Well, okay. You can make that argument. I don't find it to be a serious argument. I mean, even if at some point force was appropriate– It's quite clear over time that force is not appropriate. What do you do with that? Well, some people look at it and say, well, this is a problem. Now, in that circumstance, qualified immunity arguably wasn't really an issue. We were talking about criminal liability for the officers involved. Okay. But step that back and look at some of the other tapes that we've seen of folks who being harmed, maybe being treated in ways that they probably shouldn't have been treated. I'll give us an example, and this is not prejudging the matter. I don't know that there will be a case or what have you. I'm just talking about how we might experience it differently. Think about how Senator Padilla was treated at the Kristi Noem press conference. We've seen the video that we've seen, and I am pretty sure that if we give it to a number of different people, in part because of what we've heard through the news, et cetera, different people have different ways of viewing that particular tape. What I will do is just note this piece of the puzzle. The first thing you ask is, what was the problem? Not surprisingly, Senator Padilla says, I was just asking questions, questions that I could not get answers to from Secretary Noem for. Okay. Okay, we might well say, well, fine, a press conference isn't the place to do that. Okay, so what was the problem? Well, you could at best say the problem was that Senator Padilla was interrupting a press conference. Okay, so what happens when you interrupt a press conference? Well, presumably, you want to stop the interruption of the press conference. Okay, Senator Padilla was interrupting shoved out of the room. He was physically taken out of the room. One might say manhandled, but he was removed from the room. Once he was removed from the room, we no longer have a disruption of the press conference. So the question now becomes, why do you put him on the ground and handcuff him? My guess is that there are many people from the public's perspective who would say, that's a fine question. If the problem, to the extent that from what we saw in the video, there was nothing other than a U.S. senator asking questions at a press conference, yes, out of turn, fine. If you view it as a disruption to the press conference, once the disruption is over, it's not clear what force would need to be used. From the public's perspective, or many people in the public's perspective, I imagine the response would be, yes, that means that whatever force that was used was more force than was necessary. It was excessive force. I suspect that there are other people, in fact, I know there are other people because other people have claimed it, who would say, well, all they did was detain him after moving him out of the room. Okay, you've got two very different views of the same incident, an incident that we saw on video. So I think that's a part of what's going on is perspective is what changes our notion of what's going on. And seeing it on video is something that makes us say, oh. That doesn't really look necessary, even though we've seen much harsher tactics and physical force used with other people in other videos. I imagine some people would say, whoa, they were relatively gentle with Senator Padilla. Okay. If you've never been forced to the ground and handcuffed, okay. Yeah, I mean, yes, there are harsher ways to do it, but it's not clear that it needs to be done at all, which is part of the issue.

Katie Crawford-Lackey: 23:50

I like the way that you laid that thought process out of, okay, what's going on here? What's the problem? What's causing it? How do we handle the problem in a way that helps identify different perspectives, but when force is necessary up to the point of problems resolved, but force is still being used. And I'm wondering, it makes me think about the split second decisions, not that this example was one, but There are moments where officers are faced with circumstances where they have to react quickly. How can the law enforcement officers in a room make split-second decisions while still protecting individuals' constitutional rights?

Henry Chambers, Jr.: 24:34

It's a great question. Here's where I think courts get involved and many of my colleagues would say qualified immunity is one step farther than that. That's this. For most split-second decisions... they're already covered. For split-second decisions that are true matters of 50-50, jump ball, we would say, well, that was okay because that was a reasonable decision. Given that it was a reasonable decision, we're not going to view that particular behavior as being problematic. So that behavior itself is likely going to be deemed to be perfectly constitutional and perfectly acceptable. If you're talking about a split-second decision, what you really have to be talking about is a split-second decision that was so horrible that we would say it was unconstitutional. And that's the point at which qualified immunity could step in and say, yeah, even though the decision was horrible, horrible enough to be over the line, we're still going to provide you with some measure of coverage and safety. That's where things get interesting. Because again, we're always talking, we're talking about qualified immunity, even though some people would push back and say, to the extent that qualified immunity is being used before we have an adjudication, it doesn't always cover situations that are unconstitutional. I am fine with that. I understand that. We talked about that with Jameson versus McClendon. What I am saying though, is the point of qualified immunity is to say, even in circumstances where one may have acted in an unconstitutional manner, they're covered. So I think most... split-second decisions that are inside the realm of what we think of as being reasonable. It's something where, hey, you had to act. Those are, largely speaking, already covered as being constitutional. It's only when you're acting in a way where we go, you didn't have to do that, that we then say it's unconstitutional. And then we go to the second question of, is it covered by qualified immunity?

Katie Crawford-Lackey: 26:35

I want to return to the topic of police discretion, particularly since you're here at Montpelier today. You'll be instructing a law enforcement seminar on this topic in part. Where does the training of law enforcement come in, particularly as we think about police discretion in this context?

Henry Chambers, Jr.: 26:54

It's a great question. It's a huge question. A lot of it is about training. The question or a question is, what do we mean by training? That is one of the phrases that's used quite a bit out there is de-escalation. It's always great to try to de-escalate. One question we can ask is whether one has a constitutional obligation to de-escalate or is de-escalation just the way we ought to live our lives? And that turns out to be kind of an interesting question. In an area that is arguably tangential or slightly orthogonal to this question, we can ask the same question about stand your ground laws. We as a people are arguably moving away from de-escalation in various circumstances. Because a lot of the stuff in terms of, when you think about stand your ground laws, in many circumstances, de-escalation would have worked a whole lot better, but we're telling people you're under no obligation to de-escalate. You can do what you want to do. Now, that's the reason why I say, if we talk to police officers and we say- De-escalation is a good thing. I mean, de-escalation was not really something that was a huge issue when I was younger. Even though it was a good idea, it's not like there was discussion about your obligation is to de-escalate. But ask yourself today, should police be required to de-escalate or is it just a really good idea? Because the mere fact it's a really good idea doesn't necessarily mean that it would be unconstitutional to not de-escalate. It just means that we would look at the police officer and maybe, maybe say, is this really the profession for you if you don't want to engage in de-escalation with civilians? If your notion is that you want to go in and use the maximum force that you are allowed to use- No more than that, because clearly if you're using more than the maximum force that you're allowed to use, you really shouldn't be here. But if your notion is, I'm going to go in and use as much force as I need to deal with this situation, as opposed to saying, no, actually, I'd rather move it to a place where we're not using force at all. Is that something that's preferable? And I think the answer is it's preferable, but it doesn't necessarily get at what's constitutional and what's not constitutional. And that's something where we as citizens, civilians, in conversation with law enforcement, need to think about those issues in terms of asking, what is it that we want? And it may well be that the notion is law enforcement, they've got the message. It's just a question of sometimes folks don't always do exactly what they're trained to do. So it's a long way of getting to the question of, In terms of training, one of the questions we have to ask is, what are you being trained to do? That can also get at the question of what kind of law enforcement are we talking about? What's appropriate and what's not? A for example is we've seen protests this past weekend. We had protests and various governors, et cetera, decided going to call out the National Guard. Our president said, I'm also going to get Marines involved in the ICE situation in Los Angeles. Now, one question is, are you really sure that police who are trained to know about how to deal with these situations, are you sure that you want some other entity that's not really trained in this to come in and help out for law enforcement purposes? I trust local police to to be trained to handle most circumstances like those that we've seen around the country. Now, let me be clear because some people I'm sure would say, there you go, flacking for the police. Look, I'm not flacking for the police. What I will say though is if there are folks who are trained to take care of these situations, local police are the ones who are most likely to be trained to take care of the situation. It's not clear that National Guard or police Armed forces are the ones who you want in this situation because that's just not what they do. So that's another piece as well is who do you have, who's trained, how are they trained, and what's their mindset? Is their mindset to be de-escalatory force or is their mindset because of the way they've been trained, okay, use force to take care of the situation? We see it, sometimes we'll see it in movies. as well, where, oh, the FBI shows up and they go nuts. Local law enforcement has this taken care of and the FBI shows up and they'll take care of this the way they want to. Or we'll see it where regular police officers are there and all of a sudden people call in SWAT. You're saying, okay, is this really necessary? And sometimes the answer is yes. And sometimes the answer may be yes, even though the public doesn't realize that the answer is yes. But that's part of the discussion that we as the public need to have with law enforcement about how we want law enforcement to work. The best law enforcement can be law enforcement that avoids situations as opposed to law enforcement that handles situations in the same way that I would say for fire departments. I'd rather have a fire department that has trained the public to avoid fires rather than say, well, our fire department, we put out fires. Yes, when you don't have a choice, you put out fires. But most firemen I know would prefer to not have fires occur at all because if there's a fire, someone's either getting hurt or property's being damaged, or there's the possibility that firefighters will be harmed. So those are sort of ways of thinking about the situation in context when talking about training. that can allow us to say, well, yeah, training matters. It matters a lot. And part of what matters is the mindset you have when you come into training.

Katie Crawford-Lackey: 33:16

And as we kind of wrap up the conversation today, I'm interested to hear to you as an expert in this field, what would a truly balanced approach to discretion and accountability look like? A

Henry Chambers, Jr.: 33:32

truly balanced approach... would require that heavy interaction from the start. That is, the public needs to know what to expect of law enforcement. Law enforcement needs to know what is expected of them. And if we continue to have that conversation so that both sides recognize what each side is worried about or concerned about, that'll get us a whole lot closer to where we need to be. There's also in some ways a misconception out there that anyone who questions police in a particular circumstance doesn't like the police, I've tried to explain to people. And whenever I'm in front of groups talking about police work, because police stuff is a small part of what I do, but every now and again, I'll talk to folks. I'll say, look, let's assume that 90% of police officers are fantastic. And they'll say, okay. I said, in fact, let's just make clear this. Look at your own workforce. Do you think 90% of your coworkers are awesome? And that always draws a chuckle. Because the answer is, of course not. It's like, exactly. So I am painting a picture of the police force that is far more positive than you would paint of your own workforce. But now that means that 10% aren't awesome. And that 10% who aren't awesome, let's say that 10% is really good 50% of the time. So for four hours of their eight hour shift, they're awesome. For the other four hours, they're not necessarily so great. And they've got a badge on. and they've got a gun and they've got the right, the ability to walk up to people and start to interact in a way that people might not like. Small percentage of police work, but it has huge issues. Why? Because the person who's not living up to the standard has a badge and a gun and authority. The more discussions we have between the public and the police The better it will get. Will it ever be perfect? Probably not. But in a number of situations, what you're going to have is what I've seen in certain circumstances, which is there are a lot of people who are supportive of the police, even as they're wary of them. And that needs to be a recognition is it's not a problem to be wary, but supportive of someone. I'm very supportive of lots of entities, but I sure am wary of them as well. So those are things that we have to understand and have to recognize. If we do that, then I think we're more likely to get to a place where at least we can understand why certain things are the way they are. And we can understand that the fuzziness that goes with tests that rely on reasonableness, et cetera, we might be more likely to give the benefit of the doubt to law enforcement if we've had these conversations over time and we say, it was a mistake, but it's a mistake we can understand, particularly if that mistake doesn't necessarily come with broken bones. And that's one place where when you get to de-escalation and things along those lines, you might get to a point where folks at least understand one another and we understand police officers have a tough job. We get that. Lots of people have tough jobs. So let's hold people responsible. And we probably also ought to pay them what they're worth the same way we ought to pay teachers what they're worth, et cetera, and so forth.

Katie Crawford-Lackey: 36:57

Professor Chambers, thank you for giving us a really good overview of what qualified immunity is, but also what you discussed really underscores this importance of trust and building trust between police officers and their departments, but also the community building trust. It's a two-way relationship, obviously, and, you know, this is a collective good, a communal good, and to establish that trust, you noted, like, we're working towards it, but that's why we have conversations. And that's why we tried to engage and build that rapport. So I appreciate you laying all of that out and kind of bringing it back to that point. So thank you.

Henry Chambers, Jr.: 37:38

Much appreciated, Katie.

Katie Crawford-Lackey: 37:39

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