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''Lombardo v. City of St. Louis'', 38 F.4th 684, 689 (8th Cir. 2022).
 
''Lombardo v. City of St. Louis'', 38 F.4th 684, 689 (8th Cir. 2022).
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In district court within the Eighth Circuit, positional asphyxiation was absurdly referenced in a challenge to methods of [[capital punishment]]:
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{{cquote|Petechial hemorrhages are seen in deaths resulting from mechanical or positional asphyxia; they can result from seizure activity and hypoxia}}
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''McGehee v. Hutchinson'', 463 F. Supp. 3d 870, 899 (E.D. Ark. 2020).
 
== Fifth Circuit ==
 
== Fifth Circuit ==
 
Only 17 decisions by the [[Fifth Circuit]] have ever accepted this term, the most prominent of which merely cited the [[Tenth Circuit]]:
 
Only 17 decisions by the [[Fifth Circuit]] have ever accepted this term, the most prominent of which merely cited the [[Tenth Circuit]]:
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