Ninth Circuit
Fontana v. Haskin, 262 F.3d 871, 881 (9th Cir. 2001) (“There is no situation that would justify any amount of purposeful sexual verbal and physical predation against a handcuffed arrestee. No risk of flight nor threat to officer safety exists to justify such an abuse of the one-sided power arrangement that arises from a custodial arrest such as this one. If the jury believes Fontana, she will have proved that Haskin deprived her of her Fourth Amendment right to be free from unreasonable seizure.”).