held that the First Amendment protects a passenger who livestreams the traffic stop of the car he is traveling in. “Controversial” Doctrines Thwart the Vindication of Constitutional RightsQualified Immunity Strikes AgainThe Fourth Circuit held that qualified immunity bars Sharpe from obtaining monetary compensation (“damages”) directly from the officers for the constitutional violation, finding that it was not “clearly established” at the time of the traffic stop that prohibiting Sharpe from livestreaming violated the First Amendment. They have been criticized for being atextual, ahistorical, and driven by policy considerations