official would understand that what he is doing violates that right.” Anderson v. Creighton, 483 U.S. 635, 640, 107 S.Ct. 3034, 3039, 97 L.Ed.2d 523 (1987). The plaintiff bears the burden of showing that the constitutional right allegedly violated was clearly established “before the defendant acted or failed to act.” Rice v. Burks, 999 F.2d 1172, 1174 (7th Cir.1993) (citing Rakovich v. Wade, 850 F.2d 1180 (7th Cir.), cert. denied, 488 U.S. 968, 109 S.Ct. 497, 102 L.Ed.2d 534 (1988)). This requires the plaintiff to offer either a closely analogous case or evidence that the defendants’ conduct is so patently violative of the constitutional right that reasonable officials would know without guidance from the courts. See Rice, at 1173-74; McDonald v. Haskins, 966 F.2d 292 (7th Cir.1992) (<HOLDING>). To determine the applicability of qualified
holding that deputies use of a police dog is subject to excessive force analysis 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 a police officer was not liable for use of excessive force since  951 requirements were satisfied holding that an officer intentionally hitting the plaintiffs head into the top of the police car as the plaintiff was being placed in the police car could be excessive force holding a gun to the head of a child and threatening to pull the trigger is plainly excessive force so closely analogous case is not needed to put police officer on notice