Eighth Circuit
Coequyt v. Holien, 20-CV-1178 (PJS/TNL), at *23 (D. Minn. Aug. 11, 2022) (“It was also clearly established by April 2018 that ‘it is unreasonable to ignore a person’s complaints of pain resulting from an officer’s use of force.'”).
Howard v. Kansas City Police Dept., 570 F.3d 984, 991 (8th Cir. 2009) (stating that “it was clearly established that the Fourth Amendment was violated if an officer unreasonably ignored the complaints of a seized person that the force applied by the officer was causing more than minor injury”).