Tanner v. Walters

Actual malice is not required to succeed on 4th Amendment malicious prosecution claim, but defendant must have made deliberate or reckless falsehoods; mere negligence will not create liability; fact that police officer did not make decision to prosecute does not absolve officer from liability, where officer included falsehoods in investigatory materials, knowing that prosecutorial reliance was likely and those materials actually influenced prosecutors decision to bring charges.