improper punishment

Morris v. Zefferi, 601 F.3d 805, 812 (8th Cir. 2010) (“Transporting a pretrial detainee in a small, unsanitary dog cage for ninety minutes, with no compelling urgency and other alternatives available, under the above precedent, sufficiently shows the possible infringement of a clearly established constitutional right to be free from improper punishment.”).

Martinez v. Turner, 121 F.3d 712, at *2 (8th Cir. 1997) (stating that “the law was clearly established that a pre-trial detainee could not be punished for refusing to work”).

Green v. Baron, 925 F.2d 262, 263 (8th Cir. 1991) (stating that “pretrial detainees cannot be punished, and that a deprivation imposed on a pretrial detainee may amount to punishment if it is not reasonably related to a legitimate governmental objective or is excessively harsh in light of the objective to be served”).