In Devenpeck v. Alford, the Supreme Court will consider two issues. First, the Court will settle a conflict among the circuit courts in determining how precise an officer's stated reasons for probable cause must be to the actual arresting offense. Two judicial circuits find an arrest reasonable if, based on an objective assessment by a reasonable officer, there is probable cause to arrest for any offense. On the other hand, at least five judicial circuits find an arrest to be reasonable only if there is probable cause to arrest for crimes "closely related" to the crime or crimes articulated by the arresting officer. The Court will likely find the narrow approach more appealing and allow arrests for only "closely related" offenses. Second, the Court will decide if the law regarding arrests for "closely related" offenses was clearly established at the time of Alford's arrest. The Court will likely find the law was not settled, and thereby overrule the Ninth Circuit's decision in Alford v. Haner, et al. 333 F.3d 972 (9th Cir. 2003).