concurring in part and dissenting in part.
Because I disagree with the majority’s finding of qualified immunity for defendant, I must dissent from Part I of the Court’s opinion.
Government officials performing discretionary functions have qualified immunity shielding them from civil liability if their actions do not violate clearly established statutory or constitutional rights of which a reasonable person would have known. Harlow v. Fitzgerald, 457 U.S. 800, 818, 102 S.Ct. 2727, 2738, 73 L.Ed.2d 396 (1982). In other words, qualified immunity is available if a reasonable police officer could have believed that her conduct was lawful, in light of clearly established law. Anderson v. Creighton, 483 U.S. 635, 641, 107 S.Ct. 3034, 3039-40, 97 L.Ed.2d 523 (1987). If officers of reasonable competence could disagree as to the lawfulness of the conduct, immunity should be recognized. Malley v. Briggs, 475 U.S. 335, 341, 106 S.Ct. 1092, 1096, 89 L.Ed.2d 271 (1986).
At the time of Jeffers’ arrest, the law was clearly established that an arrest must be supported by probable cause. It was also clearly established that probable cause, “a probability or substantial chance of criminal activity,” Illinois v. Gates, 462 U.S. 213, 243 n. 13, 103 S.Ct. 2317, 2335 n. 13, 76 L.Ed.2d 527 (1983), is to be determined by reviewing the totality of the circumstances. Gates, 462 U.S. at 238, 103 S.Ct. at 2332.
Thus, in deciding whether Heavrin has qualified immunity, this Court must consider whether in the “totality of the circumstances” known to Heavrin, she reasonably could have thought she possessed probable cause to arrest Jeffers. Creighton, 483 U.S. at 641, 107 S.Ct. at 3039-40; Fuller v. M.G. Jewelry, 950 F.2d 1437, 1453 (9th Cir.1991).
At the time Heavrin arrested Jeffers, she was aware of various information. Attempting to enter an enclosed area containing horses, grass and dust, Jeffers identified medication in a pill bottle as allergy medicine. The allergy medicine had a prescription, which was in Jeffers name. Jeffers’ physician was accessible to Heavrin, for his name and telephone number was on the pre-' scription. The Physician’s Desk Reference, an encyclopedia picturing and identifying hundreds of pharmacological pills was also available to Heavrin. Finally, Heavrin had direct access to four narcotics officers.
Despite these circumstances, Heavrin arrested Jeffers based on a second hand statement, delivered by a non-narcotics officer, that the pills might be valium. In an earlier proceeding, this Court characterized the statement as insignificant, because it was unclear who thought the pills were valium, and because “the four narcotics officers who were on the premises not only deny making any identification of the pills as valium but also indicate it would have been clear to them that the pills were not valium.” Jeffers v. Heavrin, 932 F.2d 1160, 1164 (6th Cir.1991). Even the majority acknowledges that the information on which Heavrin based her arrest was “negligently secured.”
In finding qualified immunity, however, the majority attributes the reasonableness of the arrest to “the potential for unruly crowds causing personal injuries” and “the ‘contribution’ that illegal drugs and alcohol make to' crowds getting out of hand.” While I recognize the impact illegal drugs and unruly crowds have upon the mindset of a reasonable officer, I believe the objective facts available to Heavrin, in the totality of the circumstances, do not reasonably suggest she had probable cause to arrest Jeffers. Heavrin disregarded all expert and reliable resources established to accurately identify contraband without infringing upon liberty rights of spectators. A reasonable police officer would not have ignored available information from the Physician’s Desk Reference, a trained narcotics officer or Jeffers’ doctor before effecting an arrest. See Merriman v. Walton, 856 F.2d 1333, 1335 (9th Cir.1988).1 A reasonable officer, although apprehensive about illegal drugs and unruly crowds, would not arrest an individual without examining information available under *384the totality of the circumstances and establishing probable cause.
. I do not imply that officers always have a duty to investigate. Rather, I suggest that under these circumstances, no reasonable police officer would have arrested Jeffers. The reasonable officer would have inquired further.