to intervene” as a linguistic tool to highlight how little personal participation the defendant had in the arrest in that particular case. The passage shows how far below the required minimum level of involvement that particular defendant exhibited. Read in whole, Brown more accurately shows that personal participation in an arrest, or supervisory control over the arresting officer, is required in order to establish liability for unlawful arrest — mere presence is not enough. However, even assuming Plaintiffs are correct, and that law enforcement officers have a duty to intervene in other officer’s unlawful arrests, it cannot be said that the Canine Handlers or Alma Officers violated clearly established law in this case. See, e.g., Jones v. Cannon, 174 F.3d 1271, 1286 (11th Cir.1999) (<HOLDING>). The Canine Handlers and Alma Officers were
holding that inquiry as to whether officers are entitled to qualified immunity for use of excessive force is distinct from inquiry on the merits of the excessive force claim holding that an officer could be held liable for failing to intervene in preventing an unlawful strip search holding that a military police officer was entitled to qualified immunity from an excessive force suit when he objectively reasonably believed that he used reasonable force holding that while case law generally indicates that an officer can be held liable for failing to intervene in another officers use of excessive force the absence of authority from the supreme court or the eleventh circuit dealing with similar circumstances supported granting qualified immunity to a defendant holding that a police officer was not liable for use of excessive force since  951 requirements were satisfied