First Circuit
Cosenza v. City of Worcester, 355 F. Supp. 3d 81, 96 (D. Mass. 2019) (“While the Court is unaware of any caselaw explicitly holding this type of procedure is unnecessarily suggestive, the First Circuit has held that when an officer’s conduct is so clearly unconstitutional, no precedent directly on point is necessary to provide adequate notice to a reasonable officer.”).
Second Circuit
Rojas v. Iannatto, 2003 WL 169798, at *4 (S.D.N.Y. Jan. 24, 2003) (“Manson, which . . . defines a criminal defendant’s right not to be subjected to unduly suggestive identifications, has been the law since 1977.”).
Sixth Circuit
Gregory v. Louisville, 444 F.3d 725, 747 (6th Cir. 2006) (“Accordingly we find that the district court correctly denied [the defendant] qualified immunity for plaintiff’s claim of suggestive identification [in 1992].”).
Seventh Circuit
Sanders v. City of Chicago Heights, 2016 WL 2866097, at *10 (N.D. Ill. May 17, 2016) (“Indeed, it has been clearly established since at least 1977 that a criminal defendant has a due process right not to be subjected to unduly suggestive identifications that taint his criminal trial.”).