4th Circuit

Excessive or unnecessary destruction of property during a search may violate the Fourth Amendment; standard is objective reasonableness, but officers are afforded a degree of discretion and are not required to use least possible destructive methods; factors include amount of damage and the relation between damage and object of the search.

Malice may be inferred from lack of probable cause; post arrest forensic examination arguably vitiated probable cause; and cases cited therein.

Officers could not ignore forensic results that became available in the course of routine investigations, and were liable for continuing detention of innocent suspect.