ankle turn control technique as Jones did. Jennings, 2005 WL 2043945, at *7. It is not necessary to discuss this finding. 42 . Other circuits have taken a similar approach to particularity in the context of Fourth Amendment reasonableness inquiries, especially in excessive force cases. See Walker v. City of Orem, 451 F.3d 1139, 1151 (10th Cir.2006) (noting in a Fourth Amendment unreasonable detention case that "allegations of constitutional violations that require courts to balance competing interests may make it more difficult to find the law ‘clearly established' when assessing claims of qualified immunity” (quoting Medina v. City & County of Denver, 960 F.2d 1493, 1498 (10th Cir.1992)) (internal quotation marks omitted)); Williams v. Kaufman County, 352 F.3d 994, 1012 (5th Cir.2003) (<HOLDING>); Priester v. City of Riviera Beach, 208 F.3d
holding that an officer applying for a warrant without probable cause may be entitled to qualified immunity but is not entitled to absolute immunity holding that prolonged detention was unlawful but affirming qualified immunity because applicable supreme court law which allowed a seizure without probable cause when the proper balance was struck between law enforcement and personal security interests failed to put officer on notice holding that qualified immunity applies only if an officer had arguable probable cause to arrest holding that although jury found officer not to have had probable cause for arrest officer was entitled to immunity because law was not clearly established as to circumstances in which officer found himself holding qualified immunity unavailable because there was no government interest to balance