St. Paul, Minn. police receive word that a man has a gun outside a bar in a rough area of town; they show up in force, point guns at occupants of car outside the bar, none of whom match the description of the suspect. (Turns out the suspect was inside the bar, and he had a hammer.) An officer takes an occupant of the car to ground by means of an arm-bar takedown. District court: Which could be excessive force, even though the occupant did not suffer any permanent injuries. Eighth Circuit: Indeed. No qualified immunity.