Whatever the benefits of clearly established rules for judicial economy and police latitude, they may not always result in just outcomes.
In the Pennsylvania death penalty case of Wetzel v. Lambert, the prisoner filed a writ of habeas corpus based on possible Brady v. Maryland violations regarding allegedly suppressed exculpatory and impeaching material.
Citing the clearly established provision of the Antiterrorism and Effective Death Penalty Act (AEDPA), the Court sent the case back to the Third Circuit to consider the state court's reasoning that the withheld evidence was ambiguous and thus not material.
According to the opinion: "Any retrial here would take place three decades after the crime, posing the most daunting difficulties for the prosecution. That burden should not be imposed unless each ground supporting the state court decision is examined and found to be unreasonable under AEDPA." (Italics in original)
The California case of Ryburn v. Huff involved a Section 1983 lawsuit arising from a warrantless search of a Burbank home. Police brutality Section 1983 cases can arise form unconstitutional searches just as they can from unconstitutional seizures like excessive force.
In Ryburn the Court decided that the police officers were not liable under Section1983. They enjoyed qualified immunity because a reasonable police officer might have felt entry was justified by possible danger.
In fact, the Court appeared to chastise the panel majority of the Ninth Circuit that decided against qualified immunity because that panel "did not heed the District Court's wise admonition that judges should be cautious about second-guessing a police officer’s assessment, made on the scene, of the danger presented by a particular situation."