In June 2018, in Lozman v. City of Riviera Beach, the Supreme Court held 8-1 that the existence of probable cause for arrest does not categorically bar a First Amendment claim for damages. At issue in the case was the City of Riviera Beach’s arrest of resident Fane Lozman as he spoke against public corruption during a city council meeting. In this Article, we contend that Lozman is a victory–but not an unqualified one–for protesters, like those affiliated with the Black Lives Matter movement, who criticize the police and face a danger of retaliatory arrest. After Lozman, we argue that Monell suits against high-level police department officials who cause retaliatory arrests against protesters are more likely to be successful. Suits of this nature are critical to law enforcement accountability and the freedom of speech. At the same time, we recognize the narrowness of the Court’s Lozman holding and the obstacles it may impose on protester–plaintiffs’ First Amendment claims against individual police officers and against police departments for arrests made contemporaneously to speech. We conclude by examining the Court’s grant of certiorari in a *50 closely related case, Nieves v. Bartlett. We offer some thoughts about the open questions from Lozman that Nieves may resolve, and the attendant consequences for the First Amendment rights of protesters critical of the police.