Cir.2000) (“a plaintiff need not always identify a closely analogous case” to show that a violation is “clearly established”). As discussed above, Officer Cantrell’s continued detention of Bowden after frisking him and finding no weapons and without having any suspicion that Bowden was engaged in criminal behavior violated clearly established law. Courts spend substantial time discussing the reasonableness of suspicion needed to warrant a Terry stop and the proper scope of a Terry stop, but there is no question that an officer must suspect an individual of committing a crime and being threatening, rather than generally insolent, to warrant continued detention, particularly in handcuffs. See generally United States v. Place, 462 U.S. 696, 700-707, 103 S.Ct. 2637, 77 L.Ed.2d 110 (1983) (<HOLDING>); Terry v. Ohio, 392 U.S. 1, 17-22, 88 S.Ct.
recognizing that an officer must have a reasonable articulable suspicion that the person has been is or is about to be engaged in criminal activity to frisk an individual for weapons and must have probable cause to conduct a further seizure holding that an officer  may detain a person in order to determine identity and circumstance when that officer has a reasonable suspicion supported by articulable facts that criminal activity may be afoot holding that absent probable cause to arrest a police officer may approach an individual to conduct a brief investigatory stop when the officer has a reasonable articulable suspicion that criminal conduct is afoot holding that a police officer may order an individual out of his car and frisk him for weapons if there is a reasonable belief that the individual is armed and dangerous holding that an officer can stop an individual if the officer has reasonable articulable suspicion that criminal activity is underfoot