CA9 & OR: Merely citing 4A without substantive argument is waiver

“Plaintiffs forfeited their Fourth Amendment qualified immunity arguments because the opening brief makes no legal argument that qualified immunity does not apply, nor is such an argument apparent from Plaintiffs’ factual recitation.” Ramirez v. Zimmerman, 2021 U.S. App. LEXIS 32726 (9th Cir. Nov. 3, 2021).*

“Based on the circumstances known to the officers at the time of the arrest, we conclude that it was reasonable for the officers to infer that defendant was in possession of a car that he would have had reason to believe was stolen. At a minimum, the officers had probable cause to arrest for P[ossession of a] S[tolen] V[ehicle] and that is all they needed to make the arrest.” Defendant’s Fourth Amendment claim is waived for lack of argument. State v. McCall, 315 Or. App. 538. 2021 Ore. App. LEXIS 1548 (Nov. 3, 2021).*