Eighth Circuit
Nieters v. Holtan, No. 22-2600, at *10 (8th Cir. Oct. 11, 2023) (stating that “in Smith v. Kansas City, Missouri Police Department, we held it was clearly established that an officer violates a citizen’s rights by ‘knocking a non-resisting suspect to the ground . . . .'”).
Hagen v. Palmer, CIV.024318(RHK/AJB), 2003 WL 22136067, at *3 (D. Minn. Sept. 12, 2003) (stating that “a reasonable officer would have fair warning to know that it was unlawful to cause severe injury during a pat down to a suspect who poses no safety threat, cooperates, and does not resist arrest. . . . While Palmer states that he was trained in this move and has done it hundreds of times without injury, that does not demonstrate that he did it properly in this instance. Misuse of a valid policing technique can turn into unreasonable force.”).