Brown v. Department of the Navy

intervening acts of prosecutor and grand jury break the chain of causation and shield the officer unless § 1983 plaintiff claiming false arrest and prosecution can show that intervening acts resulted from deception or undue pressure of officers | "Federal prosecution was only a possibility over which the State Attorney had no control...." | failure of counsel to warn client of such collateral consequences, absent actively providing misadvice, does not fall below the range of competence demanded of attorneys in criminal cases | referring to federal/state cooperation as a “welcome innovation”