Michelle Cameron v. Michelle Craig, 713 F.3d 1012 (9th Cir. 2013). · Go Syfert
Michelle Cameron v. Michelle Craig, 713 F.3d 1012 (9th Cir. 2013). Cases Citing This Book View Copy Cite
105 citation events (105 in the last 25 years) across 14 distinct courts.
Strongest positive: Hall v. City of Weed (caed, 2024-11-14)
Treatment trajectory · 2013 → 2026 · click a year to view as-of
2013 2019 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
discussed Cited as authority (verbatim quote) Hall v. City of Weed
E.D. Cal. · 2024 · signal: see · quote attribution · 1 verbatim quote · confidence high
the elements of the 8 excessive force claim under 52.1 are the same as under 1983.
discussed Cited as authority (verbatim quote) Estate of Charles Chivrell v. City of Arcata
N.D. Cal. · 2023 · signal: see · quote attribution · 1 verbatim quote · confidence high
california, however, has rejected the monell rule and imposes liability on municipalities 5 under the doctrine of respondeat superior for acts of municipal employees.
discussed Cited as authority (verbatim quote) H.B. v. City of Torrance
9th Cir. · 2019 · signal: see · quote attribution · 1 verbatim quote · confidence high
the elements of the excessive force claim under the bane act are the same as under 1983.
discussed Cited as authority (verbatim quote) Stroud v. Gore
S.D. Cal. · 2019 · signal: see · quote attribution · 1 verbatim quote · confidence high
the elements of the excessive force claim under 52.1 are the same as under 13 1983.
discussed Cited as authority (quoted) Villarreal v. Correa
D. Nev. · 2025 · signal: see · quote attribution · 1 verbatim quote · confidence high
the fact that a suspect denies an essential element of a crime does not 4 automatically negate probable cause.
discussed Cited as authority (quoted) Montelongo v. City of Modesto
E.D. Cal. · 2021 · signal: see · quote attribution · 1 verbatim quote · confidence high
the elements of the excessive force claim under 52.1 are the same as 25 under 1983.
discussed Cited as authority (quoted) Gonzalez v. County of Fresno
E.D. Cal. · 2020 · signal: see · quote attribution · 1 verbatim quote · confidence high
plaintiff has not identified any custom or policy of the county.... the county is 26 therefore entitled to summary judgment on the 1983 claim.
cited Cited as authority (rule) Leonid P. Krivolenkov v. Matthew Bigoni, Garrett Grimm, Jason Hubert, Sarah Kerwin, Clackamas County, and City of Portland
D. Or. · 2025 · confidence medium
IV; Cameron v. Craig, 713 F.3d 1012, 1021 (9th Cir.2013) (citation omitted).
discussed Cited as authority (rule) Radni Ghafoori v. Officer Duncan, et al.
E.D. Cal. · 2025 · confidence medium
Cal. 2024) (“Courts 11 have held that Bane Act claims may be maintained against municipalities based on vicarious 12 liability[.]”), citing Cameron v. Craig, 713 F.3d 1012, 1023 (9th Cir. 2013) and Cal. Gov.
discussed Cited as authority (rule) Faison v. Alameda County
N.D. Cal. · 2025 · confidence medium
Bane Act Claim 9 To succeed on a Bane Act claim, a plaintiff must show “(1) intentional interference or 10 attempted interference with a state or federal constitutional or legal rights, and (2) the interference 11 or attempted interference was by threats, intimidation or coercion.” Allen v. City of Sacramento, 12 234 Cal. App. 4th 41, 67 , 183 Cal. Rptr. 3d 654, 676 (2015), as modified on denial of reh’g (Mar. 13 6, 2015) (citations omitted). “[T]he elements of the excessive force claim under § 52.1 are the 14 same as under § 1983.” Cameron v. Craig, 713 F.3d 1012, 1022 (9th Cir. 2…
discussed Cited as authority (rule) (PS) Hanible v. County of Solano Sheriff's Office
E.D. Cal. · 2025 · confidence medium
Cal. 3 2024) (“Courts have held that Bane Act claims may be maintained against municipalities based on 4 vicarious liability” citing Cameron v. Craig, 713 F.3d 1012, 1023 (9th Cir. 2013) and Cal. Gov. 5 Code 815.2(a)). 6 As to the first time period, Defendants are entitled to summary judgment on the Bane Act 7 claim, as there was no interference with Plaintiff’s constitutional rights. 8 As to the second and third time periods, Defendants are not entitled to summary judgment 9 on the Bane Act claim, for largely the same reasons identified as to the excessive force analysis 10 under § 198…
cited Cited as authority (rule) Roberts v. County of Kern
E.D. Cal. · 2025 · confidence medium
Opp’n at 13–14 (alterations omitted) 15 (quoting Cameron v. Craig, 713 F.3d 1012, 1021 (9th Cir. 2013)).
discussed Cited as authority (rule) Stein v. Costco Wholesale Corporation Dba Costco Wholesale 685
9th Cir. · 2024 · confidence medium
In doing so, we “must determine whether, viewing the evidence in the light most favorable to the nonmoving party, there are any genuine issues of material fact and whether the district court correctly applied the relevant substantive law.” Cameron v. Craig, 713 F.3d 1012, 1018 (9th Cir. 2013) (quoting Lopez v. Smith, 203 F.3d 1122, 1131 (9th Cir. 2000) (en banc)). 1.
discussed Cited as authority (rule) Johnson v. City of Santa Rosa
N.D. Cal. · 2024 · confidence medium
Bane Act (California Civil Code § 52.1) 5 To succeed on a claim under the Bane Act, a plaintiff must show “(1) intentional 6 interference or attempted interference with a state or federal constitutional or legal rights, and (2) 7 the interference or attempted interference was by threats, intimidation or coercion.” Id. at 67. 8 Further, “the elements of the excessive force claim under § 52.1 are the same as under § 1983.” 9 Cameron v. Craig, 713 F.3d 1012, 1022 (9th Cir. 2013).
discussed Cited as authority (rule) Hampton v. Tom'e
D. Alaska · 2024 · confidence medium
Case No. 3:24-cv-00094-JMK, Hampton v. Tucker, et al. dissipate probable cause,54 but they have no duty to investigate further or look for additional exculpatory evidence after probable cause is established.55 However, in accordance with the elements of the malicious prosecution tort, a Fourth Amendment claim for malicious prosecution requires a plaintiff to show a favorable termination of the underlying criminal case against him.56 In Heck, a prisoner brought a civil rights action for compensatory and punitive money damages against state officials who had allegedly engaged in unconstitutional…
discussed Cited as authority (rule) Hampton v. Cockrell
D. Alaska · 2024 · confidence medium
Case No. 3:24-cv-00094-JMK, Hampton v. Tucker, et al. dissipate probable cause,54 but they have no duty to investigate further or look for additional exculpatory evidence after probable cause is established.55 However, in accordance with the elements of the malicious prosecution tort, a Fourth Amendment claim for malicious prosecution requires a plaintiff to show a favorable termination of the underlying criminal case against him.56 In Heck, a prisoner brought a civil rights action for compensatory and punitive money damages against state officials who had allegedly engaged in unconstitutional…
discussed Cited as authority (rule) Hampton v. Tucker
D. Alaska · 2024 · confidence medium
Case No. 3:24-cv-00094-JMK, Hampton v. Tucker, et al. dissipate probable cause,54 but they have no duty to investigate further or look for additional exculpatory evidence after probable cause is established.55 However, in accordance with the elements of the malicious prosecution tort, a Fourth Amendment claim for malicious prosecution requires a plaintiff to show a favorable termination of the underlying criminal case against him.56 In Heck, a prisoner brought a civil rights action for compensatory and punitive money damages against state officials who had allegedly engaged in unconstitutional…
discussed Cited as authority (rule) Hampton v. Woodmen
D. Alaska · 2024 · confidence medium
Case No. 3:24-cv-00094-JMK, Hampton v. Tucker, et al. dissipate probable cause,54 but they have no duty to investigate further or look for additional exculpatory evidence after probable cause is established.55 However, in accordance with the elements of the malicious prosecution tort, a Fourth Amendment claim for malicious prosecution requires a plaintiff to show a favorable termination of the underlying criminal case against him.56 In Heck, a prisoner brought a civil rights action for compensatory and punitive money damages against state officials who had allegedly engaged in unconstitutional…
cited Cited as authority (rule) Cadiente v. City and County of Honolulu
D. Haw. · 2024 · confidence medium
Wallis v. Spencer, 202 F.3d 1126 , 1144 n.16 (9th Cir. 2000); Cameron v. Craig, 713 F.3d 1012, 1023 (9th Cir. 2013).
cited Cited as authority (rule) The Estate of Cecil Elkins. Jr. v. Hipolito Pelayo
9th Cir. · 2023 · confidence medium
Agency, 261 F.3d 912 , 922 (9th Cir. 2001) (assault and battery); Cameron v. Craig, 713 F.3d 1012, 1022 (9th Cir. 2013) ( Cal. Civ.
cited Cited as authority (rule) The Estate of Cecil Elkins. Jr. v. Hipolito Pelayo
9th Cir. · 2023 · confidence medium
Agency, 261 F.3d 912 , 922 (9th Cir. 2001) (assault and battery); Cameron v. Craig, 713 F.3d 1012, 1022 (9th Cir. 2013) ( Cal. Civ.
discussed Cited as authority (rule) Christopher Griffin v. Kristofer Asla
9th Cir. · 2023 · confidence medium
Officers may not disregard facts that dissipate probable cause, United States v. Ortiz-Hernandez, 427 F.3d 567, 574 (9th Cir. 2005) (per curiam), but they have no duty to investigate further or look for additional exculpatory evidence after probable cause is established, Cameron v. 3 Craig, 713 F.3d 1012, 1019 (9th Cir. 2013).
discussed Cited as authority (rule) Reva Nicole English v. Commonwealth of Virginia
Va. Ct. App. · 2023 · confidence medium
Once probable cause is established, ‘an officer is under no duty to investigate further or to look for additional evidence which may exculpate the accused.’” Cameron v. Craig, 713 F.3d 1012, 1019 (9th Cir. 2013) (quoting Broam v. Bogan, 320 F.3d 1023, 1032 (9th Cir. 2003)).
discussed Cited as authority (rule) Nilsson v. Baker County, Oregon
D. Or. · 2022 · confidence medium
“Once probable cause is established, ‘an officer is under no duty to investigate further or to look for additional evidence which may exculpate the accused.’” Cameron v. Craig, 713 F.3d 1012, 1019 (9th Cir. 2013) (citing Broam v. Bogan, 320 F.3d 1023, 1032 (9th Cir. 2003)).
discussed Cited as authority (rule) Griffin v. Asla
D. Or. · 2022 · confidence medium
And “[o]nce probable cause is established, ‘an officer is under no duty to investigate further or to look for additional evidence which may exculpate the accused.’” Cameron v. Craig, 713 F.3d 1012, 1019 (9th Cir. 2013) (quoting Broam, 320 F.3d at 1032 ); see Ewing, 588 F.3d at 1277 (“Once he has probable cause, an officer is not ordinarily required to investigate or seek further corroboration.”).
discussed Cited as authority (rule) Narciso v. County of San Diego
S.D. Cal. · 2022 · confidence medium
Stating a claim for excessive force in 16 violation of the Fourth Amendment states a claim for excessive force under the Bane Act 17 because “the elements of the excessive force claim under § 52.1 are the same as under § 18 1983.” Cameron v. Craig, 713 F.3d 1012, 1022 (9th Cir. 2013). 19 Additionally, in Mendez v. County of Los Angeles, the Ninth Circuit explained that 20 “the California Supreme Court has held that immunity applies only to policy decisions, not 21 to operational decisions like the [officers’] decision to enter the [plaintiff's] residence.” 897 22 F.3d 1067 , 1084 (…
discussed Cited as authority (rule) Polanco v. State of California
N.D. Cal. · 2022 · signal: cf. · confidence medium
See, e.g., Rodriguez v. Cty. of Los Angeles, 891 F.3d 776 , 801–02 12 (9th Cir. 2018) (excessive force); Reese, 888 F.3d at 1035–36 (same); cf. Cameron v. Craig, 713 F.3d 1012, 1022 (9th Cir. 13 2013) (stating, a bit imprecisely, that “the elements of [an] excessive force claim under § 52.1 are the same as under § 14 1983”).
discussed Cited as authority (rule) Cline v. Roberts
N.D. Cal. · 2021 · confidence medium
Reese v. County 1 language of Section 52.1 gives no indication that the ‘threat, intimidation, or coercion’ must be 2 independent from the constitutional violation.”) (citing Cornell v. City and County of San 3 Francisco, 17 Cal. App. 5th 766, 795 (Cal. Ct. App. 2017), as modified (Nov. 17, 2017)). 4 “The Bane Act civilly protects individuals from conduct aimed at interfering with rights 5 that are secured by federal or state law, where the interference is carried out “by threats, 6 intimidation or coercion.” Reese, 888 F.3d at 1040 (citing Venegas v. County of Los Angeles, 153 7 C…
discussed Cited as authority (rule) Lee v. Stone
D. Idaho · 2021 · confidence medium
And as the Court has previously explained, once probable cause is established, “an officer is under no duty to investigate further or to look for additional evidence which may exculpate the accused.” Cameron v. Craig, 713 F.3d 1012, 1019 (9th Cir. 2013) (citing Broam v. Bogan, 320 F.3d 1023, 1032 (9th Cir. 2003)).
cited Cited as authority (rule) Murrietta-Golding v. City of Fresno
E.D. Cal. · 2021 · confidence medium
See Moore v. City of Berkeley, 801 F. App’x 480 , 483 21 (9th Cir. 2020); Cameron v. Craig, 713 F.3d 1012, 1022 (9th Cir. 2013); Arpin v. Santa Clara 22 Valley Transp.
discussed Cited as authority (rule) Lee v. Stone
D. Idaho · 2020 · confidence medium
In 2001, in Arpin v. Santa Clara Valley Transportation Agency, 261 F.3d 912, 925 (9th Cir. 2001), the Ninth Circuit held “officers may not solely rely on the claim of a citizen witness that he was a victim of a crime to establish probable cause, but must independently investigate the basis of the witness’ knowledge or interview other witnesses.” Two years later, however, in Broam v. Bogan, 320 F.3d 1023, 1032 (9th Cir. 2003), and without mentioning Arpin, the Ninth Circuit held there is no general duty to further investigate a claim of innocence or the lack of criminal intent, “once pr…
discussed Cited as authority (rule) Tan Lam v. City of Los Banos
9th Cir. · 2020 · confidence medium
We evaluate Fourth Amendment excessive use of force claims for objective reasonableness, asking “whether the officers’ actions are ‘objectively reasonable’ in light of the facts and circumstances confronting them.” Graham v. Connor, 490 U.S. 386, 397 (1989). “[B]ecause questions of reasonableness are not well- suited to precise legal determination, the propriety of a particular use of force is generally an issue for the jury.” Barnard v. Theobald, 721 F.3d 1069, 1076 (9th Cir. 2013) (quoting Cameron v. Craig, 713 F.3d 1012, 1021 (9th Cir. 2013) (quoting Chew v. Gates, 27 F.3d 143…
discussed Cited as authority (rule) Strong v. City of Vallejo
E.D. Cal. · 2020 · confidence medium
Moreover, the Reese court clarified that, although 3 the Ninth Circuit had previously found that only a constitutional 4 violation was needed to succeed on a Tom Bane Act claim, those 5 cases “did not address whether the [] Act required some showing 6 of intent in addition to showing the constitutional violation.” 7 Id. at 1044 (citing Chaudhry, 751 F.3d at 1105 ; Cameron v. Craig, 8 713 F. 3d 1012, 1022 (9th Cir. 2013)). 9 Thus, to succeed on this claim, plaintiff must show (1) 10 that defendant Tonn violated his constitutional rights using 11 excessive force, and (2) that Tonn had a spec…
cited Cited as authority (rule) United States v. Brandon Bennett
9th Cir. · 2020 · confidence medium
But this does not negate any of the “facts necessary to the finding of probable cause.” Cameron v. Craig, 713 F.3d 1012, 1020 (9th Cir. 2013) (internal quotation marks omitted).
cited Cited as authority (rule) Arthur Moore v. City of Berkeley
9th Cir. · 2020 · confidence medium
See Susag v. City of Lake Forest, 115 Cal. Rptr. 2d 269, 276 (Ct. App. 2002); Cameron v. Craig, 713 F.3d 1012, 1022 (9th Cir. 2013).
discussed Cited as authority (rule) Robert Reese, Jr. v. County of Sacramento
9th Cir. · 2018 · confidence medium
Likewise, at the conclusion of trial, the district court rejected Defendants’ proposed alternative California Civil 2 Chaudhry relied on Cameron v. Craig, 713 F.3d 1012, 1022 (9th Cir. 2013) for the proposition that “the elements of [an] excessive force claim under § 52.1 are the same as under § 1983.” Id. 18 REESE V.
cited Cited as authority (rule) Victor Ochoa v. Director of Uscis
9th Cir. · 2018 · confidence medium
Cameron v. Craig, 713 F.3d 1012, 1018 (9th Cir. 2003).
discussed Cited as authority (rule) Harrison Orr v. Terrence Plumb
9th Cir. · 2018 · confidence medium
We agree. “[T]he elements of [an] excessive force claim under § 52.1 are the same as under § 1983” if the plaintiff “asserts no California right different from the rights guaranteed under the Fourth Amendment.” Cameron v. Craig, 713 F.3d 1012, 1022 (9th Cir. 2013). 6 Shoyoye v. County of Los Angeles, 137 Cal. Rptr. 3d 839 (Ct. App. 2012), did not hold that in all Bane Act claims the coercion and the act violating a legal right must be independent.
discussed Cited as authority (rule) Cornell v. City and County of San Francisco
Cal. Ct. App. · 2017 · confidence medium
(See Cameron v. Craig (9th Cir. 2013) 713 F.3d 1012, 1022 [“[T]he elements of the excessive force claim under § 52.1 are the same as under § 1983.”]; Batchelder v. Allied Stores Corp. (1985) 393 Mass. 819 , 822–823 [ 473 N.E.2d 1128, 1131 ] [“the Legislature intended to provide a remedy under [MCRA], coextensive with 42 U.S.C. § 1983 . . . , except that the Federal statute requires State action whereas its State counterpart does not”].) In a broad conceptual sense, that is true, since both Section 52.1 and the MCRA are supplements to Section 1983, providing state law civil remedie…
discussed Cited as authority (rule) Cornell v. City and County of San Francisco
Cal. Ct. App. · 2017 · confidence medium
(See Cameron v. Craig (9th Cir. 2013) 713 F.3d 1012, 1022 [“[T]he elements of the excessive force claim under § 52.1 are the same as under § 1983.”]; Batchelder v. Allied Stores Corp. (1985) 393 Mass. 819 , 822–823 [ 473 N.E.2d 1128, 1131 ] [“the Legislature intended to provide a remedy under [MCRA], coextensive with 42 U.S.C. § 1983 . . . , except that the Federal statute requires State action whereas its State counterpart does not”].) In a broad conceptual sense, that is true, since both Section 52.1 and the MCRA are supplements to Section 1983, providing state law civil remedie…
discussed Cited as authority (rule) Cornell v. City and County of San Francisco
Cal. Ct. App. · 2017 · confidence medium
(See Cameron v. Craig (9th Cir. 2013) 713 F.3d 1012, 1022 [“[T]he elements of the excessive force claim under § 52.1 are the same as under § 1983.”]; Batchelder v. Allied Stores Corp. (1985) 393 Mass. 819 , 822–823 [ 473 N.E.2d 1128, 1131 ] [“the Legislature intended to provide a remedy under [MCRA], coextensive with 42 U.S.C. § 1983 . . . , except that the Federal statute requires State action whereas its State counterpart does not”].) In a broad conceptual sense, that is true, since both Section 52.1 and the MCRA are supplements to Section 1983, providing state law civil remedie…
discussed Cited as authority (rule) Shock v. Las Vegas Metropolitan Police Department (2×) also: Cited "see"
9th Cir. · 2017 · confidence medium
We review de novo, Cameron v. Craig, 713 F.3d 1012, 1018 (9th Cir. 2013), and we affirm.
discussed Cited as authority (rule) Claborn v. Yuma County
Ariz. Ct. App. · 2017 · confidence medium
Additionally, “once probable cause is established, an officer is under no duty to investigate further or to look for additional evidence which may exculpate the accused.” Cameron v. Craig, 713 F.3d 1012, 1019 (9th Cir. 2013) (citation and quotations omitted).
cited Cited as authority (rule) Development Specialists, Inc. v. Meritage Homes Corp.
9th Cir. · 2015 · confidence medium
Cameron v. Craig, 713 F.3d 1012, 1018 (9th Cir.2013).
cited Cited as authority (rule) Parklyn Bay Co. v. Liberty Insurance
N.D. Cal. · 2015 · confidence medium
The court must view the evidence, and draw all reasonable inferences therefrom, “in the light most favorable to the nonmoving party.” Cameron v. Craig, 713 F.3d 1012, 1018 (9th Cir.2013).
discussed Cited as authority (rule) Boarman v. County of Sacramento
E.D. Cal. · 2014 · confidence medium
Dist., 149 Cal.App.4th 860, 883 , 57 Cal.Rptr.3d 454 (2007). “[T]he elements of the excessive force claim under § 52.1 are the same as under § 1983.’” Chaudhry v. City of Los Angeles, 751 F.3d 1096, 1105 (9th Cir.2014) (quoting Cameron v. Craig, 713 F.3d 1012, 1022 (9th Cir.2013)).
cited Cited as authority (rule) Veronica Ollier v. Sweetwater Union High School
9th Cir. · 2014 · confidence medium
See Fed.R.Civ.P. 56(a); Cameron v. Craig, 713 F.3d 1012, 1018 (9th Cir.2013).
discussed Cited as authority (rule) John Hernandez v. Kevin Broin
9th Cir. · 2014 · confidence medium
We have jurisdiction under 28 U.S.C. § 1291 and affirm. 1 A district court’s order granting summary judgment is reviewed de novo to “determine whether, viewing the evidence in the light most favorable to the nonmov-ing party, there are any genuine issues of material fact and whether the district court correctly applied the relevant substantive law.” Cameron v. Craig, 713 F.3d 1012, 1018 (9th Cir.2013) (quoting Lopez v. Smith, 203 F.3d 1122, 1131 (9th Cir.2000) (en banc)).
cited Cited as authority (rule) George Clinton v. Hendricks & Lewis Pllc
9th Cir. · 2014 · confidence medium
Cameron v. Craig, 713 F.3d 1012, 1018 (9th Cir.2013).
cited Cited as authority (rule) PACIFIC MARINE CENTER, INC. v. SCOTT SILVA
9th Cir. · 2014 · confidence medium
Cameron v. Craig, 713 F.3d 1012, 1021 (9th Cir.2013) (citing Pearson v. Callahan, 555 U.S. 223, 236 , 129 S.Ct. 808 , 172 L.Ed.2d 565 (2009)).
Retrieving the full opinion text from the archive…
Michelle CAMERON, Plaintiff-Appellant,
v.
Michelle CRAIG; County of San Diego, Defendants-Appellees
11-55927.
Court of Appeals for the Ninth Circuit.
Apr 16, 2013.
713 F.3d 1012
2013 WL 1607488
2013 U.S. App. LEXIS 7563
James Matthew Brown, Law Office of James Matthew Brown, San Diego, CA; Vanessa M. Ruggles (argued), Palm Springs, CA, for Plaintiff-Appellant., David Axtmann, Senior Deputy County Counsel (argued), San Diego, CA, for Defendants-Appellees.
McKeown, Smith, Bell.
Cited by 86 opinions  |  Published
3 passages pin-cited by 3 cases
Pinpoint authority: #32,866 of 633,719
Citer courts: E.D. California (2) · D. Nevada (1)

[*1015] OPINION

M. SMITH, Circuit Judge:

Michelle Cameron appeals the district court’s order granting summary judgment in favor of Defendants Michelle Craig and the County of San Diego (collectively, the County Defendants). Cameron alleges that her Fourth Amendment rights were violated when the County Defendants obtained a warrant to search her home without probable cause, used excessive force while executing that warrant, and then arrested her. She also brought related claims under California law. Because there was probable cause to search Cameron’s residence and to arrest Cameron, we affirm the district court’s entry of judgment with respect to those claims. Because disputed issues of material fact remain regarding Cameron’s excessive force and conspiracy claims, however, we reverse and remand those claims to the district court for further proceedings consistent with this opinion.

FACTUAL BACKGROUND [1]

Michelle Cameron worked as a yoga instructor in San Diego. One of her students was San Diego County Sheriffs Deputy David Buether. The two began dating in 2004, and eventually moved in together. Some months later, Cameron became pregnant. Cameron gave birth to the couple’s first child in October 2006.

Sometime afterwards, the couple agreed that Cameron should quit her job in order to work as a full-time mother. The couple opened a joint checking account, and because Cameron had no independent source of income, she also frequently used Buether’s credit card to make purchases for herself and the family. Although Cameron and Buether were never married, Cameron believed the couple’s finances were completely intermingled. [2]

Cameron and Buether had a second child in March 2008, but their relationship soured later that year when Cameron learned that Buether was having affairs with multiple women. After two alleged incidents of domestic violence, Buether obtained an ex parte restraining and “kick out” order against Cameron. She was removed from the family home by San Diego County Sheriffs Deputies the following day. As she was leaving, Cameron asked Buether what she was supposed to do without any belongings. Buether told her to “do what you need to do.”

On October 9, 2008, Cameron moved into a friend’s house. A few days later, she used Buether’s credit card to purchase furniture and housewares for her new residence. In total, Cameron purchased nearly $9,000 worth of beds, tables, chairs, and other furnishings from Overstock.com for herself and her (and Buether’s) children.

Toward the end of October 2008, Buether rescinded the restraining order against Cameron, and the couple’s children began splitting time between their parents. The couple also entered mediation in the hope of resolving child custody issues. While mediation was ongoing, Buether attempted to reconcile with Cameron, and spent the night at Cameron’s residence on two occa[*1016] sions. Commenting on the new furniture, Buether told Cameron that once the couple got back together, they would sell all of the duplicative items on eBay.

Cameron, however, refused to reconcile with Buether. Buether, individually and through his lawyer, then demanded that Cameron repay him for the furniture. Cameron refused.

On November 14, 2008, Buether filed a criminal complaint with the San Diego County Sheriffs Department, claiming that an “unknown suspect” had used his credit card without authorization to purchase items from Overstock.com. Buether told the sheriffs that he thought Cameron might be responsible for the disputed transactions. Buether further indicated that he wanted to press charges should a suspect be apprehended.

San Diego County Sheriffs Detective Michelle Craig was assigned to investigate Buether’s claims. Craig and Buether had attended the Sheriffs Academy together, and had worked on the same shift at the Vista Patrol Station for four years. During that time, Craig and Buether responded to hundreds of calls together, and Cameron alleges that Craig and Buether were Mends. Both Craig and Buether insist they did not maintain a social relationship outside of work.

On November 17, 2008, Craig began investigating Buether’s claims. First, Craig called Overstock.com, which confirmed that it shipped the disputed items to Cameron at her new address, and that Buether’s credit card was used for payment. Second, Craig interviewed Buether. Buether informed Craig that he and Cameron had lived together for four years, that Cameron had recently moved out because she was violent and unstable, and that he had seen some new furniture and furniture boxes at Cameron’s residence when he visited her there. Buether also informed Craig that while he had given Cameron permission to use his credit card in the past, he had always been present when the credit card was used, and that he did not give Cameron permission to make these specific purchases. Finally, Buether told Craig that he had confronted Cameron about the disputed credit card charges during one of the couple’s custody mediation sessions. Buether told Craig that Cameron responded, “Oh, you mean our joint credit card,” and then promptly changed the subject. Craig then showed Buether pictures of some of the items that had been charged to Buether’s credit card, and Buether confirmed he had seen similar items inside Cameron’s home.

On December 15, 2008, Craig applied for a warrant to search Cameron’s apartment for the purchased items. Craig’s supporting affidavit read, in relevant part, as follows:

Michelle Cameron and the victim began dating and living together approximately four years ago. They have had two children together, but were never married. Their relationship deteriorated and in September 2008 there was an unreported domestic violence incident ... On 10/08/08, the victim obtained a restraining order against Michelle which also ordered her out of the residence ... The victim later rescinded the restraining order, which is no longer valid. On 10/13/08, Michelle Cameron placed three different internet orders on Overstock.com purchasing items totaling $8,969.39. Michelle used U.S. Bank Visa credit card number [] to pay for the purchases. That credit card belongs solely to the victim, her ex-boyfriend, who did not authorize the transactions. Invoices obtained from Overstock.com during this investigation document the shipping address, phone number, and email addresses, which all belong to Mi[*1017] chelle Cameron. I showed the victim photos of possible items purchased by Michelle, and he stated he has seen the following stolen items inside her residence as of 3 to 4 weeks ago [ ] ... Based on my training and experience and the above investigation, I believe there is a substantial likelihood that stolen property will be present when I execute this warrant because Michelle Cameron purchased those items in order to furnish her new home after being ordered out of her prior residence and some of the items, such as beds, are being used for her and her children to sleep on.

A deputy district attorney reviewed the warrant affidavit, and certified his belief that it was legally sufficient. A San Diego County Superior Court judge issued the warrant that same day.

Soon after the search warrant issued, Buether provided Craig with his custody schedule. One of the days Buether indicated Cameron would have custody of the couple’s children was December 18, 2008. Craig asked whether Buether would be available to pick up his children if Cameron were arrested. Buether indicated that he could pick up the children at any time.

Craig also conducted background checks on all of the known residents of Cameron’s apartment. Craig uncovered no information indicating that any of the residents would be armed, and had no reason to suspect that Cameron or any other resident might pose a threat to officer safety. However, Craig was unable to complete a background check on one suspected resident.

At 7:00 a.m. on December 18, 2008 — a time Craig knew Cameron would have custody of her two young children — Craig and six to ten other San Diego County Sheriffs Deputies executed the search warrant at Cameron’s residence. [3] Upon arrival, the deputies knocked, announced themselves, and demanded entry. One of Cameron’s roommates admitted the deputies. The deputies were armed and had their weapons drawn. They were dressed entirely in black, with bulletproof vests and helmets. The deputies went upstairs, where they encountered Cameron in a hallway outside her bedroom. Multiple deputies aimed their weapons at Cameron, who was trying to alert the officers to the presence of her children in an adjacent bedroom. Cameron repeatedly implored the deputies not to scare her small children, and pointed toward the children’s bedroom. In response, the deputies grabbed Cameron by the arms and shoulders and pushed her in the back to force her out of the hallway. [4] The deputies pushed Cameron into the living room, where her arms were pulled behind her back and she was handcuffed. Cameron testified that the handcuffs were applied tightly enough to leave a bruise that lasted for a few days. Cameron was then seated on a couch while the Sheriffs Deputies conducted their search.

In the meantime, Craig phoned Buether to come and pick up the children, which Buether did shortly thereafter. Craig then interviewed Cameron, who explained that she believed she was an authorized user on Buether’s credit card, that she had used his credit card frequently in the past, and that she thought Buether had given her permission to use the credit card to[*1018] purchase the disputed items. At the conclusion of the interview, Cameron was arrested for identity theft, grand and petty theft, and fraudulent use of an access card. She was transported to county jail. That same day, Buether called the mediator overseeing the couple’s custody dispute to inform him that Cameron had been arrested. Cameron was released from jail five days later. The District Attorney declined to prosecute Cameron, and all charges were voluntarily dismissed.

PROCEDURAL BACKGROUND

Cameron brought suit against Buether and the County Defendants on November 6, 2009. [5] Cameron complained that Buether and the County Defendants conspired to violate, and did violate, her Fourth and Fourteenth Amendment rights when they unlawfully searched her home pursuant to an invalid search warrant, used excessive force in the execution of that warrant, and arrested her without probable cause. Cameron also brought state law claims for negligence, harassment, false arrest, and violation of California Civil Code § 52.1.

After Cameron had twice amended her complaint, the County Defendants moved to dismiss Cameron’s negligence claim. [6] The district court granted the County Defendants’ motion with prejudice. On November 18, 2010, the County Defendants moved for summary judgment with respect to Cameron’s remaining claims. The County Defendants’ motion was granted on March 4, 2011, and final judgment was entered on May 13, 2011. Cameron timely appeals.

JURISDICTION AND STANDARD OF REVIEW

We have jurisdiction to review the district court’s entry of judgment under 28 U.S.C. § 1291. We review a grant of summary judgment de novo, “and must determine whether, viewing the evidence in the light most favorable to the nonmoving party, there are any genuine issues of material fact and whether the district court correctly applied the relevant substantive law.” Lopez v. Smith, 203 F.3d 1122, 1131 (9th Cir.2000) (en banc).

DISCUSSION

I. Constitutionality of the Search

Cameron claims her home was unlawfully searched pursuant to an invalid search warrant. To be valid, a search warrant “must be supported by an affidavit establishing probable cause.” United States v. Stanert, 762 F.2d 775, 778 (9th Cir.1985). Probable cause exists where, under the totality of the circumstances, a reasonable officer has occasion to believe that the search will uncover evidence relating to a suspected crime. See Illinois v. Gates, 462 U.S. 213, 230-31, 103 S.Ct. 2317, 76 L.Ed.2d 527 (1983); Brinegar v. United States, 338 U.S. 160, 175-76, 69 5.Ct. 1302, 93 L.Ed. 1879 (1949). The test is an objective one, and the “actual motivations of the individual officers involved ... play no role in” the Fourth Amendment analysis. Whren v. United States, 517 U.S. 806, 813, 116 S.Ct. 1769, 135 L.Ed.2d 89 (1996).

[*1019] The warrant to search Cameron’s home issued on the basis of Detective Craig’s affidavit. Our review of that affidavit confirms what the issuing judge previously determined — that the totality of the circumstances described therein provided probable cause to search Cameron’s residence. Among other crimes, Cameron was suspected of fraudulently using Buether’s credit card to obtain valuable property. See CaLPenal Code § 484g (anyone who “obtains money, goods, services, or anything else of value by representing •without the consent of the cardholder that he or she is the holder of an access card and the card has not in fact been issued, is guilty of theft”); see also People v. Molina, 120 Cal.App.4th 507, 15 Cal.Rptr.3d 493, 495-96 (2004) (a credit card is an “access card” for the purposes of § 484). In her affidavit, Craig averred that Buether did not authorize Cameron to use his credit card and that Overstock.com confirmed that Buether’s credit card was used to purchase items worth nearly $9,000. On their own, these statements were sufficient to establish probable cause to suspect that Cameron had violated § 484g of the California Penal Code. Craig’s further allegations — that Overstock.com shipped the purchased items to Cameron’s home address, and that Buether saw what he believed to be at least some of the purchased items inside Cameron’s home — were sufficient to establish probable cause to search Cameron’s home for evidence of her suspected crime(s). Thus, the search warrant was facially valid.

Cameron advances two alternative theories to explain why the search, despite being conducted pursuant to a facially valid warrant, nevertheless violated her constitutional rights. First, Cameron argues that the search was unconstitutional because Craig had a duty to investigate Cameron’s version of events before obtaining the search warrant. If Craig had learned Cameron’s version of events (i.e., that Cameron believed she was authorized to use Buether’s credit card), and had included that story in the warrant application, Cameron claims the search warrant would never have issued. We cannot credit this argument. The fact that a suspect denies an essential element of a crime does not automatically negate probable cause. While best practices may dictate that the police obtain both sides of a story where practicable, the law simply does not mandate such diligence. [7] Once probable cause is established, “an officer is under no duty to investigate further or to look for additional evidence which may exculpate the accused.” Broam v. Bogan, 320 F.3d 1023, 1032 (9th Cir.2003) (citation and quotations omitted).

Second, Cameron argues that Craig intentionally excluded relevant information from her affidavit, such as Craig’s working relationship with Buether, Buether and Cameron’s ongoing custody dispute, and the extent of Buether and Cameron’s financial intermingling. It is well established that a police officer may not deliberately omit facts that would otherwise negate a showing of probable cause. See Franks v. Delaware, 438 U.S. 154, 171-72, 98 S.Ct. 2674, 57 L.Ed.2d 667 (1978).

Unfortunately for Cameron, these are not such facts. Even if the omitted material had been included, the warrant would still be supported by probable cause. See id. at 155-56, 98 S.Ct. 2674 (explaining that to establish a Fourth Amendment vio[*1020] lation, an alleged omission must be “necessary to the finding of probable cause”) (emphasis added); see also United States v. Martinez-Garcia, 397 F.3d 1205, 1214 (9th Cir.2005). By way of example, even had the affidavit referenced Cameron’s prior authorized use of Buether’s credit card, it would not necessarily undercut Buether’s claim that Cameron was not authorized to use his credit card for these specific purchases—purchases the merchant confirmed were made by Cameron. Put differently, the facts “necessary to the finding of probable cause” were the ones contained in the warrant affidavit, not those omitted by Craig. Because the search of Cameron’s home did not violate her Fourth Amendment rights, the district court properly awarded summary judgment to the County Defendants on these claims. [8]

II. Constitutionality of the Arrest

Cameron also claims the County Defendants lacked probable cause to arrest her. Largely for the reasons explained above, Part I, supra, we disagree.

When Cameron was arrested, Craig knew at least the following: (1) Buether claimed that Cameron used his credit card without authorization; (2) Overstock.com confirmed that Cameron used Buether’s credit card; (3) items purchased from Overstock.com were present in Cameron’s home; and (4) Cameron claimed that she had frequently used Buether’s credit card in the past, and thought she had permission to use Buether’s credit card to make the relevant purchases. At bottom, Craig was faced with a classic “he said, she said” situation: Buether claimed Cameron didn’t have his permission to use his credit card, while Cameron claimed that she did. Under the totality of these circumstances, an objectively reasonable officer could have chosen to believe Buether. Consequently, we cannot conclude that Cameron was arrested without probable cause. The district court properly ruled in favor of the County Defendants on Cameron’s false arrest claims.

III. Constitutionality of the Use of Force

Cameron also brings claims regarding the amount of force the County Defendants used to execute the search warrant and Cameron’s arrest. Cameron alleges that the County Defendants used “SWAT-like” tactics in order to intimidate her, and that a jury could find that the level of force employed was constitutionally excessive. The County Defendants asserted that the amount of force used was reasonable and that Craig is entitled to qualified immunity because no clearly established law put her on notice that the force employed was excessive. Because “historical facts material to the qualified immunity determination are in dispute,” Conner v. Heiman, 672 F.3d 1126, 1131 (9th Cir.2012) (internal quotation marks omitted), the district court erred in granting summary judgment to the defendants on the excessive force claim.

“[T]he Supreme Court set forth a two-part test for qualified immunity in excessive force cases. First, we examine whether a Fourth Amendment violation occurred; second, we look to see whether the officers violated clearly established law.” Santos v. Gates, 287 F.3d 846, 855[*1021] n. 12 (9th Cir.2002) (citing Saucier v. Katz, 533 U.S. 194, 121 S.Ct. 2151, 150 L.Ed.2d 272 (2001)). In Pearson v. Callahan, 555 U.S. 223, 129 S.Ct. 808, 172 L.Ed.2d 565 (2009), the Court held that lower courts may address the second step alone where it proves dispositive.

It is clearly established that “[t]he Fourth Amendment proscribes only ‘unreasonable’ searches and seizures.” Franklin v. Foxworth, 31 F.3d 873, 875 (9th Cir.1994). The reasonableness of a search or seizure depends “not only on when [it] is made, but also how it is carried out.” Tennessee v. Gamer, 471 U.S. 1, 8, 105 S.Ct. 1694, 85 L.Ed.2d 1 (1985) (emphasis added). “In other words, even when supported by probable cause, a search or seizure may be invalid if carried out in an unreasonable fashion.” Franklin, 31 F.3d .at 875 (emphasis omitted).

We have repeatedly counseled that the reasonableness of a particular search or seizure must be “assessed by carefully considering the objective facts and circumstances that confronted the [involved] officer or officers.” Chew v. Gates, 27 F.3d 1432, 1440 (9th Cir.1994) (citing Graham v. Connor, 490 U.S. 386, 396, 109 S.Ct. 1865, 104 L.Ed.2d 443 (1989)). While a court (or jury) may “look to whatever specific factors may be appropriate in a particular case,” Franklin, 31 F.3d at 876, the Supreme Court has articulated three factors that courts should typically consider: (1) the severity of the crime at issue; (2) whether the suspect poses an immediate threat to the safety of the officers or others; and (3) whether the suspect is actively resisting arrest or attempting to evade arrest by flight. Graham, 490 U.S. at 396, 109 S.Ct. 1865. Crucially, “[because questions of reasonableness are not well-suited to precise legal determination, the propriety of a particular use -of force is generally an issue for the jury.” Chew, 27 F.3d at 1440 (citations omitted); see also Coles v. Eagle, 704 F.3d 624, 628 (9th Cir.2012). “[I]n excessive force cases ... in addition to the deference officers receive on the underlying constitutional claim, qualified immunity can apply in the event [a] mistaken belief [about the amount of force required] was reasonable.” Saucier, 533 U.S. at 206, 121 S.Ct. 2151.

The factual record on the excessive force claim is not fully developed. The parties, for example, agree that the deputies entered Cameron’s residence with guns drawn, but dispute whether deputies pointed their guns at Cameron’s head. Although Cameron conceded that Craig is not personally liable for her deputies pointing guns at Cameron’s head, Cameron asserted at oral argument that Craig is liable for directly participating in the raid and in organizing it to take place at such a time and in such a manner as to be maximally intimidating. “[Wjhen the disputed facts and inferences are treated in the manner required by law,” that is, construed in Cameron’s favor, “a jury could properly find that the force used [was] greater than was reasonable under the circumstances.” Tekle v. United States, 511 F.3d 839, 846 (9th Cir.2007) (internal quotation marks omitted and second alteration in original). Cameron’s suspected crimes were relatively minor and non-violent, [9] the County Defendants had no rea[*1022] son to suspect Cameron or any of her known roommates would pose a threat to officer safety, and Cameron was not resisting arrest. The County Defendants presented no evidence to the contrary.

Nevertheless, Craig led six to ten Sheriffs Deputies into Cameron’s residence with guns drawn early in the morning. Those deputies pointed weapons at Cameron, grabbed Cameron by the arms and shoulders, pushed her in the back down a hallway, and then tightly handcuffed her. Oh this view of the facts, a reasonable jury could find that the deputies used excessive force. See, e.g., Robinson v. Solano Cnty., 278 F.3d 1007, 1013-15 (9th Cir.2002) (en banc) (aiming weapons at a suspect may, in certain circumstances, constitute excessive force); Baldwin v. Placer Cnty., 418 F.3d 966, 970 (9th Cir.2005) (pointing weapons and pushing plaintiff could constitute excessive force); LaLonde v. Cnty. of Riverside, 204 F.3d 947, 960 (9th Cir.2000) (tight handcuffing can constitute excessive force); Clash v. Beatty, 77 F.3d 1045, 1048 (7th Cir.1996) (“[Pjolice officers do not have the right to shove, push, or otherwise assault innocent citizens without any provocation whatsoever.”).

The County Defendants’ arguments to the contrary are not persuasive. For instance, the County Defendants argue that Craig was unable to ascertain the identity — and consequently the risk profile — of one of Cameron’s roommates before conducting the search. Thus, the County Defendants argue that Craig and her colleagues took reasonable precautions to protect themselves against an “unknown threat.” Perhaps, but that determination is for a jury to make, not us. Our only task is to determine whether the evidence presented “permits only one reasonable conclusion” — that the County Defendants did not use excessive force. Santos, 287 F.3d at 851. That is simply not the case here.

The County Defendants are not entitled to qualified immunity at this juncture as the record does not permit us to decide whether they violated clearly established law. “[Wjhether the officers may be said to have made a ‘reasonable mistake’ of fact or law may depend on the jury’s resolution of disputed facts and the inferences it draws therefrom.” Id. at 855 n. 12. And apart from the question of qualified immunity on the federal claims, Cameron is entitled to jury trial on her claim for excessive force under California Civil Code § 52.1, which permits civil actions for interference with rights under the United States or California Constitutions by threats, intimidation, or coercion. See Cousins v. Lockyer, 568 F.3d 1063, 1072 (9th Cir.2009) (quoting Venegas v. Cnty. of L.A., 153 Cal.App.4th 1230, 63 Cal.Rptr.3d 741, 751 (2007)) (“California law is clear that ‘[tjhe doctrine of qualified governmental immunity is a federal doctrine that does not extend to state tort claims against government employees.’ ”). Cameron asserts no California right different from the rights guaranteed under the Fourth Amendment, so the elements of the excessive force claim under § 52.1 are the same as under § 1983. See Reynolds v. Cnty. of San Diego, 84 F.3d 1162, 1170 (9th Cir.1996), overruled on other grounds, Acri v. Varian Assocs., Inc., 114 F.3d 999, 1000 (9th Cir.1997) (“Section 52.1 does not provide any substantive protections; instead, it enables individuals to sue for damages as a result of constitutional violations.”).

[*1023] IV. Conspiracy

Cameron also brings a conspiracy claim. “Conspiracy to violate a citizen’s rights under the Fourth Amendment ... is evidently as much a violation of an established constitutional right as the [underlying constitutional violation] itself.” Baldwin, 418 F.3d at 971. Cameron alleged that Craig and Buether conspired to obtain an invalid search warrant. Because we conclude the search warrant was valid, there can be no claim for conspiracy on this ground. See Lacey v. Maricopa Cnty., 693 F.3d 896, 935 (9th Cir.2012) (en banc) (recognizing that conspiracy “does not enlarge the nature of the claims asserted by the plaintiff, as there must always be an underlying constitutional violation”). But Cameron also alleged that Craig and Buether conspired regarding the timing and execution of the search. The summary judgment record reflects further facts regarding Buether’s potential involvement in Craig’s decisions regarding the manner of the search. The district court addressed and rejected the conspiracy claim only with regard to the allegation that Craig omitted relevant information from her search warrant affidavit. We conclude that Cameron is entitled to jury trial on the claim for conspiracy to use excessive force.

Cameron claims that the search warrant was executed in such a way as to intimidate her, and to secure an unfair advantage for Buether in the couple’s custody proceedings. Viewing the evidence in the light most favorable to Cameron, and drawing all reasonable inferences therefrom, we conclude that Cameron’s conspiracy claim should go to the jury. A rational jury could conclude that Craig and Buether conspired to abuse their power as law enforcement officers to deprive Cameron of her constitutional rights based on the evidence in the record that: Craig and Buether were friends and close colleagues; Craig knew Buether and Cameron were engaged in mediation over custody of their children; Craig purposefully chose to “raid” Cameron’s home on a day when she knew Cameron’s children would be present; the level of force used by Craig and the other County Defendants was clearly intimidating; and Buether sought to exploit the raid by immediately calling the couple’s mediator after Cameron was arrested. Cameron is entitled to an opportunity to prove these serious allegations at trial.

V. Municipal Liability

Finally, we address the County’s potential liability for the complained of acts of excessive force. Under federal law, the County cannot be held vicariously liable for its deputies’ acts of excessive force. The County may be held liable only if it “has adopted an illegal or unconstitutional policy or custom” that resulted in the excessive force. Robinson, 278 F.3d at 1016 (citing Monell v. Dep’t of Soc. Servs., 436 U.S. 658, 690-91, 98 S.Ct. 2018, 56 L.Ed.2d 611 (1978)). Cameron has not identified any custom or policy of the County that guided the deputies’ use of force in the search and arrest. The County is therefore entitled to summary judgment on the § 1983 claim.

The result is different with regards to Cameron’s state law claim for excessive force under California Civil Code § 52.1. Because California has rejected the Monell rule, see Cal. Gov’t Code § 815.2, state law “imposes liability on counties under the doctrine of respondeat superior for acts of county employees; it grants immunity to counties only where the public employee would also be immune.” Robinson, 278 F.3d at 1016. The defendants do not raise any state statutory immunities. Thus, should Cameron prevail on her ex[*1024] cessive force claim, liability could extend to the County.

CONCLUSION

The district court properly granted summary judgment on Cameron’s unlawful search and arrest claims. But disputed issues of material fact preclude an award of summary judgment on Cameron’s excessive force and conspiracy claims. We therefore remand those portions of Cameron’s case to the district court for proceedings consistent with this opinion.

We award the costs of this appeal to Cameron. Fed. R.App. P. 89(a)(4).

AFFIRMED IN PART, REVERSED IN PART, AND REMANDED.

1

. Because this case comes to us on summary judgment, we present the facts in the light most favorable to Cameron. See Torres v. City of Madera, 648 F.3d 1119, 1123 (9th Cir.2011).

2

. The evidence of financial intermingling is extensive. For instance, in addition to their joint checking account, Buether and Cameron were cosigners on a $125,000 home equity line to which Cameron had unrestricted access, and were also co-signers on an auto loan for a vehicle that was titled in both Buether’s and Cameron’s names.

3

. Cal.Penal Code § 1533 dictates that 7:00 a.m. is the earliest a search warrant can be executed without obtaining a judge’s special permission for night service. See abo Rodriguez v. Superior Court, 199 Cal.App.3d 1453, 245 Cal.Rptr. 617, 624-25 (1988) (describing the heightened standard for obtaining nighttime service of a search warrant).

4

. At her deposition, Cameron likened the experience to being "in a tumbler.”

5

. Buether is not a party to this appeal. In the district court, Buether did not join any of the County Defendants’ dispositive motions. Buether’s own motion for judgment on the pleadings — filed after summary judgment had already been granted in favor of the County Defendants — was denied as moot.

6

. Cameron's Third Amended Complaint (the operative complaint) no longer contains a cause of action for harassment.

7

. Cameron’s police practices expert, who was formerly the commanding officer of the San Diego County Sheriff's Department Internal Affairs Unit, testified at his deposition that it was “neglect of duty” for Craig not to interview Cameron before obtaining the search warrant.

8

. It is important to note that by rejecting Cameron's search claims, the panel in no way endorses Craig’s or Buether’s conduct here. Craig’s failure to include clearly relevant— albeit legally "unnecessary”-—details in the search warrant affidavit demonstrates, at the very least, a significant lack of professional judgment. At worst, it is evidence of a purposeful attempt to aide Buether in his alleged vendetta against Cameron. See Part IV, infra.

9

. That Cameron was suspected of relatively minor property crimes significantly undercuts the County Defendants’ arguments that the level of force used here was per se reasonable. A rational jury could easily determine that the deployment of up to ten heavily armed officers is unnecessary to execute a search warrant looking for stolen property. This is particularly true where, as here, there is no concern that the property might be moved or destroyed in the time it takes to secure the scene. Unlike drug seizures, for[*1022] instance, where a quick entry requiring multiple officers may be desirable to prevent the destruction of evidence, see, e.g., Illinois v. McArthur, 531 U.S. 326, 332, 121 S.Ct. 946, 148 L.Ed.2d 838 (2001), the property at issue here included a six-drawer dresser and a mattress.