The headline here is ambiguous and potentially misleading. The judge ruled that the QI factors weren’t met in this case and so it doesn’t apply. That happens i

The headline here is ambiguous and potentially misleading. The judge ruled that the QI factors weren’t met in this case and so it doesn’t apply. That happens in every successful 1983 case. He did not rule that QI, as a judicially created doctrine untethered from the statutory text, should no longer be applied.