be serio be expected to restrain herself from arresting speakers based upon what they say while advocating their political positions in an orderly fashion. See Houston v. Hill, 482 U.S. 451, 461-62, 107 S.Ct. 2502, 96 L.Ed.2d 398 (1987) (noting that a properly trained officer may reasonably be expected to exercise a higher degree of restraint than the average citizen). Therefore, because Leonard’s arrest was not supported by probable cause, it was error for the district court to grant Robinson qualified immunity on the Fourth Amendment claims. E The district court’s analysis of the retaliation claim under Mt. Healthy was also flawed. Because Leonard’s conduct was constitutionally protected and because arrest is particularly suited to chill this conduct, see Bloch, 156 F.3d at 679-80 (<HOLDING>), we focus on the district court’s evaluation
holding in a fcra case that plaintiffs may not rely on mere  conclusory statements  rather they must  sufficiently articulate  true demonstrable emotional distress  including the factual context in which the emotional distress arose evidence corroborating the testimony of the plaintiff the nexus between the conduct of the defendant and the emotional distress the degree of such mental distress mitigating circumstances if any physical injuries suffered due to the emotional distress medical attention resulting from the emotional duress psychiatric or psychological treatment and the loss of income if any recognizing that in some circumstances injuries based on embarrassment humiliation and emotional distress may be sufficient to sustain a  1983 claim holding that expert testimony is not required to corroborate a claim for emotional distress holding that a combination of embarrassment humiliation and emotional distress is sufficient to chill for mt healthys purposes holding that a tort claim for intentional infliction of emotional distress is distinct from a claim for emotional distress damages under the employment discrimination statute