In Malley v. Briggs (1986), the U.S. Supreme Court held that a police officer may be sued for money damages by the victim of an unlawful arrest, when that officer's complaint and the supporting affidavit which gave rise to the judicially issued warrant failed to establish probable cause for the arrest. In Anderson v. Creighton (1987), the U.S. Supreme Court ruled that a police officer who participates in a search ultimately found to be illegal may not be held personally liable for money damages so long as "a reasonable officer could have believed" the "search to be lawful, in light of clearly established law and the information the searching officers possessed." In Kirk v. City of Newark, a New Jersey State Court held that a police officer can defend against a Section 1983 civil rights suit by establishing that she acted with probable cause or, even if probable cause did not exist for the arrest, search, or seizure, that a reasonable police officer could have believed in its existence. another case establishes that a municipality may be held civilly liable for constitutional violations resulting from its failure to provide adequate training for its police officers or other municipal employees. The final case holds that a criminal defendant's voluntary release of his right to sue public officials in exchange for a dismissal of charges is not per se invalid.