Second Circuit
Terebesi v. Torreso, 764 F.3d 217, 239 (2d Cir. 2014) (“The use of a [flash-bang] grenade must be justified by the particular risk posed in the execution of the warrant.”).
Eighth Circuit
Aden v. City of Bloomington, Minn., Civ. 20-1508 (JWB/TNL), at *19 (D. Minn. Sep. 29, 2023) (“Here, the officers had notice that as of July 2, 2019, launching flashbang grenades within close range and shooting 40 mm foam rounds directly at a person who did not present an immediate threat of death or serious injury amounts to unconstitutional excessive force.”).
Z.J. by and through Jones v. Kansas City Bd. of Police Commissioners, 931 F.3d 672, 682 (8th Cir. 2019) (“The SWAT team knew the suspect, Charles, was already in custody. . . . Nor did they have any indication that other people at the residence would pose any threat. . . . The use of a flash-bang grenade under these facts was not reasonable. . . . Nor was the manner of use reasonable. They threw the flash-bang grenade into the house blindly without knowing whether children, elderly, or other innocent individuals were inside.”).