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40 Nos. 77-1698, 77-1210 & 77-1870 of a sole instigator who personally communicated with all the participants in the conspiracy and orchestrated each of their actions does not preclude a jury from con- cluding that a conspiracy existed. Plaintiffs presented sufficient evidence from which a reasonable person could find that all the defendants named in the initial conspiracy performed discreet functions in concert to further a common plan—the raid. Liability for civil conspiracy requires proof of more than an agreement among conspirators; a plaintiff must show that an actual deprivation of his rights resulted from the conspiracy. See supra, p. 36. The raid and the injuries suffered by plaintiffs as a result of the raid reasonably could be found to constitute this actuai deprivation of rights. Thus, plaintiffs have established a prima facie case under sections 1983 and 1985(3) for civil liability: a conspiracy:to violate their civil rights and actual deprivation of those rights arising from the implementation of the conspiratorial plan. IV. CLAIMS OF INDIVIDUAL LIABILITY FOR ACTS BEFORE AND DURING THE RAID As an alternative to the conspiracy allegations, plain- tiffs assert that these defendants are subject to in- dividual liability under section 1988 or directly under the Constitution. The gist of their claims is that these defendants are liable for the intentional and negligent deprivation of rights which occurred during the raid.25 *° Defendants urge that plaintiffs be denied relief on the ground that negligent conduct is not cognizable under sec- tion 1988. We are not persuaded by this argument. Defen- dants are correct that “mere negligence” is not actionable un- der 42 U.S.C. § 1983. Bonner v. Coughlin, 545 F.2d 565, 567 ue! Cir. 1976), cert. denied, 485 U.S. 932 (1978). In Jamison v. eCurrie, 565 F.2d 483, 486 (7th Cir. 1977), Chief Judge Fairchild articulated the standard for a constitutional cause of action: “The plaintiff must show that [the police officers’] misbehavior was either intentional or in reckless disregard of his constitutional rights,” citing Bonner v. Coughlin, supra. The evidence offered by plaintiffs, however, viewed in the light most favorable to them, satisfies this test. Plaintiffs’ case rests on evidence of excessive force, assault, battery, and wrongful (Footnote continued on following page)