First Circuit
Miranda-Rivera v. Toledo-Davila, 813 F.3d 64, 70-73 (1st Cir. 2016) (“There is sufficient evidence for a reasonable jury to conclude that the officers used force that resulted in disproportionately severe injuries to Rojas—e.g., multiple lacerations, contusions, and abrasions throughout his body—and ultimately in his death.”).
Fourth Circuit
Thomas v. Holly, 533 Fed. Appx. 208, 215 (4th Cir. 2013) (stating that the extent of the plaintiff’s injury is a factor for the court to consider).
Eighth Circuit
Coker v. Arkansas State Police, 734 F.3d 838, 843 (8th Cir. 2013) (stating that “a reasonable jury could find that the severity of Coker’s injuries demonstrates excessive force, particularly Cartwright’s decision to strike Coker using a metal flashlight after Coker was already on the ground and allegedly complying with Cartwright’s demands”).
Mayo v. City of Hopkins, CIV. 06-3677 DSD/SRN, 2008 WL 1924170, at *4 (D. Minn. Apr. 28, 2008) (“Considering the severe injury suffered by plaintiff, the fact that she had committed no crime, that she was not going to be arrested and that she was not arrested, the court determines that under the facts alleged by plaintiff, a reasonable officer would have understood that his actions violated the Fourth Amendment.”).
Montiel v. Liepold, CIV.06-331(JNE/JJG), 2007 WL 1994050, at *2 (D. Minn. July 5, 2007) (stating that “courts may consider the result of the force in analyzing an excessive force claim”).
Piekarski v. City of Minneapolis, CX-93-1575, 1994 WL 17497, at *2 (Minn. App. Jan. 25, 1994) (“Although a permanent injury may be indicative of excessive force, the lack of a permanent injury does not mean that the force used was not excessive.”).