Can a police officer be held liable for attorney fees incurred by a plaintiff who proves that he was arrested without probable cause?

A plaintiff who proves that police arrested him without probable cause is entitled to compensation for the economic and non-economic damages he incurs as a proximate result of these violations. Borunda v. Richmond, 885 F.2d 1384, 1389 (9th Cir.1988). Reasonable attorney's fees incurred by the plaintiff can constitute part of the foreseeable economic damages, unless the prosecutor's decision to file charges is such an independent judgment that it must be considered the proximate cause of the subsequent criminal proceedings. Id. at 1389-90.

Thus, the police officers can be liable for the costs of Barlow's defense if they acted maliciously or with reckless disregard for his rights. See Smiddy v. Varney, 665 F.2d 261, 267 (9th Cir.1981), cert. denied, 459 U.S. 829, 103 S.Ct. 65, 74 L.Ed.2d 66 (1982). They can also be liable if they made false reports to the prosecutor, omitted material information from the reports, or otherwise prevented the prosecutor from exercising independent judgment. Borunda, 885 F.2d at 1390.

The evidence in Borunda was more than sufficient to support a finding that the

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