D.C. Circuit
Polk v. District of Columbia, 121 F. Supp. 2d 56, 70-71 (D.D.C. 2000) (“In the instant case, there can be little doubt that the Constitution forbids police officers to share their authority to conduct searches and seizures with unauthorized civilians.”).
Eighth Circuit
Haynes v. Minnehan, 14 F.4th 830, 837 n.6 (8th Cir. 2021) (“Once all reasonable belief that Haynes was armed or dangerous was dispelled, he was kept publicly displayed, pants undone, in handcuffs for no legitimate purpose. Haynes was not threatening in any respect.”).
El-Ghazzawy v. Berthiaume, 636 F.3d 452, 460 (8th Cir. 2011) (stating that “a reasonable officer could not have believed it was lawful to handcuff and frisk a suspect absent any concern for safety”).