Should the doctrine of qualified immunity be limited or abolished?

QUESTIONS PRESENTED 1. Should the doctrine of qualified immunity be limited to defenses at common law when the Civil Rights Act was adopted or should it be abolished by this Court? 2. If qualified immunity is not limited or abolished by this Court, are State Employees, including Attorneys and Investigator Employees of the Attorney General’s Office and/or the New Mexico Human Services Department (State Employees) entitled to qualified immunity when they knowingly create and use false documents to prosecute a civil state court proceeding? 3. Are State Employees entitled to qualified immunity when they knowingly file that suit without probable cause and/or cause state court litigation to be prolonged because State Employees did not have vital documentation to support the case prior to its filing which is why State Employees created the false documents during the course of litigation? 4. Are State Employees entitled to qualified immunity when they further cause a deprivation of property rights without due process by termination or non-renewal of Petitioners’ Medicaid contract based upon unsubstantiated allegations of Medicaid fraud? 5. Are State Employees entitled to qualified immunity when they cause a violation of due process, either substantive or procedural by withholding money due to Petitioner Advantageous Community Services LLC on a subsequent contract on a claim of fraud involving a prior contract? 6. Does the Tenth Circuit’s holding conflict with Hope v. Pelzer, 536 U.S. 730, 741 (2002), which ii “expressly rejected a requirement that previous cases be ‘fundamentally similar” or involve “materially similar’ facts”?