Eighth Circuit
Rohrbough v. Hall, 586 F.3d 582, 587 (8th Cir. 2009) (“A jury could conclude, for instance, that Mr. Rohrbough’s push was de minimis or inconsequential, and so a reasonable officer, when faced with the present circumstances, would have known that responding by punching Mr. Rohrbough in the face, taking him to the ground face down, landing on top of him and thereby causing him serious injury was illegal.”).