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City of Anderson v. Davis2/21/2001 orce or performance of his duties in an otherwise illegal manner would not appear to take those activities outside the scope of his employment, see Weatherford, 714 N.E.2d at 186 (noting that willful and wanton behavior, and even intentional criminal conduct, may fall within the scope of employment), or beyond the realm of law enforcement. See Minks, 709 N.E.2d at 382-383 (immunizing apparently unlawful actions by police officers who instructed an intoxicated and unlicensed teenager to drive a vehicle rather than go through the effort of preparing arrest paperwork).
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