Eighth Circuit
Sanders v. Brownlee, 72 F.3d 134, at *1 (8th Cir. 1995) (“At the time of the incidents it was clearly established that retaliatory searches can form the basis of an eighth amendment claim.”).
Scher v. Engelke, 943 F.2d 921, 925 (8th Cir. 1991) (“Certainly the unlawfulness of Engelke’s retaliatory conduct must have been apparent to him. The basic course of decent human conduct precludes the infliction of such trauma on one in custody.”).