On the other hand, defendant cited two cases suggesting that in the situation outlined above, a bare-handed push would not violate the constitution. See Routt v. Howard, No. 17-CV-0020-JED-JFJ, 2018 WL 2392541, at *7 (N.D. Okla. May 25, 2018); see also Scott, 711 F. App'x 871. Plaintiff did not cite any case law that would show that it was clearly established that defendant Smith's conduct was unconstitutional, particularly when plaintiff admits that he slowed down before reaching the cell. Plaintiff instead only cited general caselaw about the use of excessive force.