What is the effect of qualified immunity on Fourth Amendment and Fourteenth Amendment claims?

^9. We also do not find it a "troubling issue" that, applying our holding, different results might be obtained when qualified immunity is raised as a post-verdict defense to both Fourth and Fourteenth Amendment claims in the same case. This is simply a feature of the differing nature of the constitutional claimsone with a subjective intent element and one without. Cf. Crawford-El v. Britton, 523 U.S. 574, 584-94 (1998) (rejecting a heightened pleading standard in cases alleging constitutional violations with a subjective intent element even though this might increase the number of subjective intent constitutional claims that would survive to summary judgment in qualified immunity cases).