A federal tort claims act case was properly stated for an American citizen plaintiff’s four day detention in an immigration facility as lacking probable cause. Hernandez v. United States, 2019 U.S. App. LEXIS 28081 (2d Cir. Sept. 17, 2019).
Defendant is denied qualified immunity for taking down the plaintiff for alleged minor offenses when he wasn’t resisting and then using excessive force against him while down. McKibben v. Knuth, 2019 U.S. App. LEXIS 28347 (9th Cir. Sept. 19, 2019).*