Dundon v. Kirchmeier
Not clearly
established as of November 2016 that use of force to disperse a crowd constitutes a
seizure; concluding from that the need for training and supervision on dispersal of
protestors was not so obvious that it can be characterized as deliberate indifference to
the protestors’ rights to be free from unreasonable seizures; for same reason,
insufficient showing of deliberate indifference by supervisors.