Sixth Circuit
Champion v. Outlook Nashville, Inc., 380 F.3d 893, 903 (6th Cir. 2004) (stating that it was “clearly established that putting substantial or significant pressure on a suspect’s back while that suspect is in a face-down prone position after being subdued and/or incapacitated constitutes excessive force”).
Johnson v. City of Cincinnati, 39 F. Supp.2d 1013, 1019-20 (S.D. Ohio 1999) (finding that information existed in the law enforcement community that put officers on notice of the dangers of positional asphyxiation).