Sixth Circuit
Guilford v. Frost, 269 F. Supp. 3d 816, 834 (W.D. Mich. 2017) (stating that “clearly established law also provides that an officer must give a suspect ‘adequate time to comply’ with an order prior to using force in connection with an arrest”).
Eighth Circuit
Wilson v. Lamp, 901 F.3d 981, 989 (8th Cir. 2018) (“Force may be objectively unreasonable when a plaintiff does not resist, lacks an opportunity to comply with requests before force is exercised, or does not pose an immediate safety threat.”).