D.C. Circuit
Shaw v. District of Columbia, 944 F.Supp.2d 43, 57-59 (D.D.C. 2013) (concluding that “a reasonable officer would know that treating a female detainee as plaintiff was treated (i.e. holding her with male detainees and otherwise treating her as if she were male) exposed her to a substantial risk of serious harm”).
Eighth Circuit
Bolin v. Wilkins, — F.4th —, 2026 WL 1252315, at *4-5 (8th Cir. 2026) (“At the time of this incident, it was clearly established that the use of a pepper spray gun absent a physical threat to others violated the Eighth Amendment … , so it was also clearly established as a violation of the Due Process Clause.” … “Deputy Wilkins should have known in 2020 that his takedown of Bolin, which included slamming Bolin’s head against the opposite wall, violated clearly established law.” … “At the time Sergeant Franks tased Bolin, it was clearly established that a non-violent detainee has a right to be free from being tased for non-compliance.”).
Fuller v. Hafoka, No. 19-CV-0886 (PJS/BRT), at *38 (D. Minn. July 19, 2021) (“Eighth Circuit precedent had clearly established by April 14, 2017, that using force without warning against a compliant pretrial detainee who was agitated but not posing an immediate safety or security threat violated the Due Process Clause.”).