Following a summary of the facts in Burns v. Reed, the holding in the case, and the rationale the U.S. Supreme Court used to reach its decision, the discussion considers the implications of the case for law enforcement agencies and their legal advisors. The case of Burns clarifies the issue of immunity for the actions of prosecutors, an issue which turns on whether the challenged action is "intimately associated with the judicial phase of the criminal process." The applicable holdings in Burns and other cases discussed suggest that any legal advice offered to police officers regarding criminal matters prior to the decision to make an arrest will be accorded only qualified immunity. For those prosecutors who approach their jobs professionally, knowledgeably, and with good faith, the decision in Burns would seem to have little effect. The case of Burns also reinforces the idea that when a police officer knows or should know that his or her actions violate an individual's rights, then hesitation and caution are reasonable responses.