Second Circuit
Edrei v. Maguire, 892 F.3d 525, 544 (2d Cir. 2018), cert. denied, 139 S. Ct. 2614 (2019) (“When engaging with non-violent protesters who had not been ordered to disperse, no reasonable officer would have believed that the use of such dangerous force was a permissible means of moving protesters to the sidewalks. Whatever legitimate interest the officers had in clearing the street, the use of sound capable of causing pain and hearing loss in the manner alleged in the complaint was not rationally related to this end.”).