Article on a way to argue cases to avoid qualified immunity issues

I just read an interesting article on an alternative way to argue cases seeking compensation against the government.  The article begins, 

Recent officer-involved shootings and public allegations of police misconduct have sparked legal discussion around accountability for law enforcement. Much of this discussion has come to focus on reforming qualified immunity, a complicated legal doctrine that can shield officers from liability in police misconduct lawsuits. However, plaintiffs may have another option for recourse that does not require grappling with qualified immunity . . .