Helseth v. Burch, 258 F.3d 867, 871 (8th Cir. 2001) (“We hold that the intent-to-harm standard of Lewis applies to all § 1983 substantive due process claims based upon the conduct of public officials engaged in a high-speed automobile chase aimed at apprehending a suspected offender.”).
Schwartz v. Anderson, 99-1254 DWF/AJB, 2001 WL 1618198, at *4 (D. Minn. May 24, 2001) (“The law was well-established at the time of the relevant incident, June 12, 1994, that police officers could be held liable for their behavior during the chase of a suspect. . . . While it is true that such liability has not been frequently found, the potential for officer liability was still established and known at the time of the incident in this case, and thus the law can be considered ‘clearly established.’”).