Protesters erect tents on University of California–Berkeley campus, form human chain to prevent police from taking the tents down. After bullhorn warnings, police use batons to disperse protesters. Excessive force? Ninth Circuit: None of the plaintiffs got really hurt, so no. Concurrence: The protest was entirely peaceful (apart from locking arms), and there was no immediate need to remove the tents. So it was excessive force; but the officers are entitled to qualified immunity because there’s no precedent that puts police on notice.