forty six Zurcher, 436 U.S. First, Zurcher does not communicate to the qualified immunity shield, and Messerschmidt retains that the protect ordinarily applies even to forty three Zurcher v. Stanford Daily, 436 U.S. 36 Messerschmidt holds that the truth that a neutral justice of the peace has issued a warrant is the clearest indication that the officers acted in an objectively reasonable method.