Second Circuit
Higazy v. Templeton, 505 F.3d 161, 174 (2d Cir. 2007) (“For the purposes of our inquiry here, we conclude that when the facts are cast in the light most favorable to Higazy, an officer in Templeton’s shoes would have understood that the confession he allegedly coerced from Higazy would have been used in a criminal case against Higazy and that his actions therefore violated Higazy’s constitutional right to be free from compelled self-incrimination.”).
Eighth Circuit
Livers v. Schenck, 700 F.3d 340, 354 (8th Cir. 2012) (“The alleged actions of Investigators Schenck, Lambert, and O’Callaghan during Livers’ interrogation potentially violated a right that was clearly established by Wilson in 2001, well before Livers was interrogated.”).
Wilson v. Lawrence County, 260 F.3d 946, 953 (8th Cir. 2001) (“There are sufficient facts in the record to support the conclusion that the officers set out to secure a confession from Wilson, and succeeded only by overreaching. Against this background case law, in light of Wilson’s limited intelligence and mental capacities, no officer could have reasonably thought this conduct consistent with Wilson’s constitutional rights.”).