Second Circuit
Palmer v. Richards, 364 F.3d 60, 67 (2d Cir. 2004) (stating that “it is possible that Palmer endured unusually harsh SHU conditions that constituted an ‘atypical and significant deprivation’ under Sandin, in which case Palmer’s right to due process protections was clearly established”).
Eighth Circuit
Jones v. Coonce, 7 F.3d 1359, 1363 (8th Cir. 1993) (“On the record before us, however, it should have been clear that thirty days was not a reasonable time for detention of Payne, Moore and McGee without an informal non-adversary hearing.”).