Sixth Circuit
Champion v. Outlook Nashville, Inc., 380 F.3d 893, 903 (6th Cir. 2004) (stating that it was “clearly established that putting substantial or significant pressure on a suspect’s back while that suspect is in a face-down prone position after being subdued and/or incapacitated constitutes excessive force”).
Johnson v. City of Cincinnati, 39 F. Supp.2d 1013, 1019-20 (S.D. Ohio 1999) (finding that information existed in the law enforcement community that put officers on notice of the dangers of positional asphyxiation).
Eighth Circuit
Standberry as Trustee for Moody v. Ramsey County, 2025 WL 1645314 at *8 (D. Minn. June 10, 2025) (“In each case, the circuit court found that the detainee had a right to be free from prone restraint in combination with pressure on the back after the detainee had stopped resisting, that law enforcement violated that right, and that the right was clearly established.”).