Fourth Circuit
Turmon v. Jordan, 405 F.3d 202, 208 (4th Cir. 2005) (stating that “it would have been clear to a reasonable officer that he could not point his gun at an individual’s face, jerk him from his room, and handcuff him when there was no reasonable suspicion that any crime had been committed, no indication that the individual posed a threat to the officer, and no indication that the individual was attempting to resist or evade detention”).
Eighth Circuit
Heard v. City of Red Wing, 393 F. Supp. 3d 785, 791 (D. Minn. 2019) (stating that “it was clearly established long before August 2016 that police could not stop or detain an individual without particularized reasonable suspicion”).
Passenheim v. Tolbert, 15-CV-0422 (PJS/SER), 2016 WL 6915504, at *1 (D. Minn. Nov. 21, 2016) (“The constitutional rights that are at issue in this case—essentially, the right not to be stopped by police without reasonable suspicion and the right not to be subject to excessive force—are clearly established.”).
Smith v. Appledorn, CIV. 11-2966 JNE/SER, 2013 WL 451320, at *5 (D. Minn. Feb. 6, 2013) (“It has been clearly established for many years that an officer cannot seize a person without having specific and articulable facts to justify the intrusion.”).
Lee v. Macias, CIV. 11-1945 DWF/FLN, 2012 WL 2126849, at *4 (D. Minn. June 12, 2012) (stating that “a reasonable officer would have known that seizing Plaintiff in the absence of a reasonable suspicion of criminal activity violated clearly established Fourth Amendment principles,” and granting in part Plaintiff’s motion for partial summary judgment).
Rayford HICKMAN, Pl., v. CITY OF MINNEAPOLIS, Minneapolis Police Dept., and Officer Scott Olson., Defendants., 02-4157, 2004 WL 1459443, at *3 (D. Minn. Feb. 10, 2004) (“Olson, a seven-year veteran of the Minneapolis Police Department, is presumed to have known that he could not detain a citizen without a reason. Olson certainly realized that he could only lawfully detain plaintiff if he could point to facts giving rise to an objectively reasonable suspicion that a crime was being committed. Plaintiff’s rights in the context of his encounter with Olson were therefore clearly established.”).
Fields v. City of Omaha, 810 F.2d 830, 835 (8th Cir. 1987) (“On June 27, 1983, when Officer Mackevicius stopped and detained Fields, the Supreme Court had clearly established the necessary conditions for a police officer’s investigative stop. A police officer may stop and briefly detain an individual whose behavior reasonably causes suspicion of criminal activity. . . . The officer’s ‘reasonable suspicion’ must be based on objective, articulable facts and reasonable inferences drawn from all the circumstances surrounding the suspect’s behavior.”).