William Rainsberger was charged with murdering his elderly mother. But the detective who built the case against him submitted a probable cause affidavit that not only contained lies about material facts, it also omitted exculpatory evidence.  Rainsberger sued the detective when charges were dropped. Detective Benner moved for summary judgment, arguing that he was entitled to qualified immunity. The detective conceded for that he knowingly or recklessly made false statements in the probable cause affidavit. But he argued that knowingly or recklessly misleading the magistrate in a probable cause affidavit only violates the Fourth Amendment if the omissions and lies were material to probable cause. The Seven Circuit disagreed that the lies and omissions were not material in the affidavit. Materiality depends on whether the affidavit demonstrates probable cause when the lies are taken out and the exculpatory evidence is added in. The court held that when that is done here, the affidavit fails to establish probable cause to believe that Rainsberger murdered his mother. Because it is clearly established that it violates the Fourth Amendment “to use deliberately falsified allegations to demonstrate probable cause,” Franks v. Delaware, 438 U.S. 154, 168 (1978), Benner is not entitled to qualified immunity.