First Circuit
Raiche v. Pietroski, 623 F.3d 30, 39 (1st Cir. 2010) (“A reasonable officer with training on the Use of Force Continuum would not have needed prior case law on point to recognize that it is unconstitutional to tackle a person who has already stopped in response to the officer’s command to stop and who presents no indications of dangerousness.”).
Sixth Circuit
Morrison v. Bd. Of Trustees Of Green Twp., 583 F.3d 394, 408 (6th Cir. 2009) (stating that “it was ‘obvious’ that Officer Celender could not push a handcuffed detainee’s face into the ground when there lacked a genuine threat to the safety of the officers or others”).
Ninth Circuit
Drummond v. City of Anaheim, 343 F.3d 1052, 1061-62 (9th Cir.2003) (holding that officer’s alleged conduct in subduing mentally ill citizen violated “clearly established” law because the court “need[ed] no federal case directly on point to establish that kneeling on the back and neck of a compliant detainee, and pressing the weight of two officers’ bodies on him even after he complained that he was choking and in need of air violates clearly established law, and that reasonable officers would have been aware of the same”).
Tenth Circuit
McCoy v. Meyers, 887 F.3d 1034, 1052–53 (10th Cir. 2018) (“Even assuming that our previous cases were not sufficiently particularized to satisfy the ordinary clearly established law standard, ours is ‘the rare obvious case, where the unlawfulness of the officer’s conduct is sufficiently clear even though existing precedent does not address similar circumstances.’”).
Eleventh Circuit
Cantu v. City of Dothan, Ala., 2020 WL 5270645 (11th Cir. 2020) (collecting cases standing for the proposition that excessive force may so obviously violate the Constitution that no pre-existing case law is needed to show that this is clearly established law).