D.C. Circuit
Shaw v. District of Columbia, 944 F.Supp.2d 43, 57-59 (D.D.C. 2013) (concluding that “a reasonable officer would know that treating a female detainee as plaintiff was treated (i.e. holding her with male detainees and otherwise treating her as if she were male) exposed her to a substantial risk of serious harm”).
Eighth Circuit
Fuller v. Hafoka, No. 19-CV-0886 (PJS/BRT), at *38 (D. Minn. July 19, 2021) (“Eighth Circuit precedent had clearly established by April 14, 2017, that using force without warning against a compliant pretrial detainee who was agitated but not posing an immediate safety or security threat violated the Due Process Clause.”).