Mary Ann Sause sued police officers and local officials under Section 1983 after officers entered her apartment in response to a noise complaint and allegedly ordered her to stop praying. She also alleged that officers acted unlawfully in entering and remaining in the apartment and refused to investigate her report of an assault. The district court dismissed the complaint on qualified-immunity grounds, and the Tenth Circuit affirmed on the First Amendment claim. The Supreme Court reversed and remanded. The First Amendment protects prayer, but whether officers could lawfully interrupt it depended on the reason they were in the apartment and what they required Sause to do. Her complaint did not clearly state whether the officers entered by consent or another lawful basis, whether their presence violated the Fourth Amendment, or what legitimate law-enforcement interest justified the order. Because a liberal reading of the pro se complaint could state Fourth Amendment claims, the lower courts could not resolve the free-exercise claim or qualified immunity without addressing those questions. The Court did not decide the ultimate constitutional merits.