 This approach shifts focus from individual officers to placing focus on police organizations.In 1982, The United States Supreme Court introduced the doctrine of qualified immunity in Harlow v. Fitzgerald.In 2001 with Saucier_v._Katz and Pearson v. Callahan the US Supreme Court allowed courts to grant qualified immunity on the basis of clearly established law or lack of precedent, without the court having to subsequently clearly established the law.