The Carotid Hold And The Arm Bar-control Hold Are Examples Of What Type Of Control?

Warning

ISSUE NO. three

A PERIODIC TRAINING GUIDE PROVIDED COMPLIMENTARY
TO PROSECUTION AND Police ENFORCEMENT AGENCIES

Utilise-OF-FORCE TACTICS AND Not-LETHAL WEAPONRY

Alarm is a periodic training guide provided without cost to the law enforcement community. Previous editions have addressed Vehicle Searches and Interrogations and Confessions. In this newspaper, we expect at some of the major employ-of-forcefulness issues and controversies facing law enforcement personnel. The debate concerning specific tactics of not-lethal weaponry is more than theoretical; the relative merits and criticisms of these have been the bailiwick of extensive litigation, with contradictory views expressed in the classrooms by law trainers and in the courtrooms by opposing skillful witnesses.

The Progression of Forcefulness

Police enforcement officers are permitted to use the degree of force that is reasonably necessary to achieve their lawful objectives and to overcome any unlawful resistance. The progression of force tin be depicted graphically, such every bit the Confrontational Continuum adult past Kevin Parsons, Ph.D. and similar models developed past others.^{Footnote ane} These models describe what have often been vague policies on this subject. Such models are also useful in litigation; they explain to the jury why an officer responded in a particular fashion. They also give the jury a standard by which they can gauge whether the utilize of strength was correct. Figure 1 depicts the Parsons Continuum, which is a linear dispatch through a progressive series of steps.

The usual first pace is verbal persuasion; the 2d is manual escort. If unsuccessful or inappropriate, the adjacent step is pain compliance. Usual methods of pain compliance include the wrist lock, arm bar or other "come-along" technique. It is only when mechanical control methods are ineffective (or non appropriate) that the forcefulness applied escalates to the apply of impact weapons.

The chief police impact weapon is the billy. It is the intermediate step between hand-practical force and the ultimate force of firearms. It should be noted that most police force trainers will consider information technology a poor practice or even negligence not to issue and train officers with a baton (except those few departments whose officers are not armed at all). The alleged negligent act is allowing officers to escalate from mitt-holds and pain compliance directly to deadly force, when the application of a greater caste of not-lethal forcefulness would likely have accomplished the objective of overcoming resistance.

Certain circumstances may warrant an accelerated reaction using a higher degree of strength when initiating a contact with a violent or dangerous person. Combative beliefs or the influence of alcohol, drugs or controlled substances (such equally PCP) could justify greater force in the initial stages.

How Control Techniques are Measured

On the one side is the likelihood of gaining control of an private; on the other is the likelihood and extent of injury. In general, techniques which accept a high propensity for causing tissue harm, hematoma or clotting and take a depression potential for control should be rejected. Conversely, methods or weapons that take a low likelihood of causing injury, but a loftier potential for command, should be encouraged.

Parenthetically, it should exist noted that some trainers have suggested that any device is suitable for utilise if a training programme and certification accompany that weapon. Many court cases have demonstrated the fallacy of that view. While compliance and control training is an accented necessity, injuries or death may still occur because of the man factors of misapplication, miscalculation, and excessive force.

The 'But-For' Statement... Failure to Assess Alternatives, Too Hasty a Response?

Often a constabulary enforcement officeholder is placed in a situation where he must resort to the apply of a weapon in defense of himself, beau officers, or a citizen. If litigation follows the upshot, an expert may testify that the officer failed, in the initial stages of the contact, to de-escalate or avert the confrontation, and that the ensuing and predictable injury or death could take been prevented by:

(a) different or improved preparation in the utilise of psychological persuasion, or

(b) the initial avoidance of conflict with the combatant -- that is, the officer should accept kept distant in a secure position until reinforcements or specialists arrived on the scene.

In this way, superior officers (such as the primary, sheriff, or director of training) may be held personally liable for a tragic issue, even though they did not directly authorrize the officer's action or deport, and were not present at the time information technology occurred. Such is the nature of the tort of administrative negligence.

IMPACT WEAPONS

In 1987 the International Association of Chiefs of Police (IACP) surveyed 2,914 police agencies, most of which were in the U.S.^{Footnote two} A series of questions related to the types of weapons issued or permitted; the percentage of agencies that had approved each weapon mentioned is indicated below:

89% three to 6 cell flashlights
16% Saps, blackjacks or sap gloves
75% Night sticks
54% PR-24 batons
50% Mace (chemical irritants or tear gas sprays)
xv% Stun guns

AELE does not approve or disapprove of the employ of any of these per se. Nosotros have attempted to list some of the major strengths and weaknesses of each of these, to assist the law enforcement community in conclusion-making in this controversial area.

The Flashlight

STRENGTHS

It is usually readily available, specially at dark; it is considered standard equipment.
It does not give the outward appearance of an offensive weapon.
It can be used with minimal reaction fourth dimension, if held in one'south manus.
The light can temporarily disorient or impair the sight of an opponent.
It is "constructive" equally an bear upon weapon, in that information technology will evangelize a heavy accident.

WEAKNESSES

Manufacturers are reluctant to approve or endorse the use of their flashlights as touch weapons. I manufacturer stated that "... it would exist irresponsible to utilise a flashlight for striking, jabbing or other offensive moves... Our company has never advocated the use of the flashlight as a weapon, nor to our noesis has any responsible flashlight manufacturer." ^{FOOTNOTE 3}
Flashlights take too short a reach for effective employ as a tactical weapon.
Flashlights provide a slower response than batons; the recovery time is not rapid enough.
Flashlights have sharp edges that will cut a person.
Multi-cell lights are very heavy; a blow to the head can be fatal or crusade permanent paralysis.
An officer who carries a weighted flashlight and a baton volition be reluctant to drop his light and pull the baton. If the officer does discard the light, information technology could be used as a weapon against him. He may therefore strike the offender with the low-cal (which is already in his manus) instead of using the baton, as he was trained.

LITIGATION EXAMPLES

A Los Angeles man recovered a jury verdict of $1,250,000 from a flashlight blow to his caput during a scuffle, following a routine traffic terminate for having a loud muffler. ^{Footnote 4}
A Pennsylvania adult female and her mother recovered $175,000 for light-headed spells resulting from a flashlight blow. ^{Footnote v}
A Virginia human being received a judgment of $one,500,000 to compensate him for spoken communication impairment and paralysis, following a flashlight blow received during a DUI traffic stop.^{Footnote 6}
A Minnesota man was awarded $35,000 in punitive damages confronting an officer who struck him with a flashlight at a tavern disturbance; his injuries were minimal (simply $2,000 in compensatory amercement were awarded). ^{Footnote seven}
A Michigan man received $200,000 for his injuries and another $250,000 in castigating damages against a police officer who broke up a bar fight. The plaintiff proved the officer struck him in the confront with a flashlight, breaking his noses. ^{Footnote 8}
Because officers are trained not to strike a person in the head with a weighted flashlight, there is the risk of criminal prosecution of officers who, under stress, react with a blow to the head of the resisting person. In such cases, the indictment may be for a felony (assault with a deadly weapon). ^{Footnote 9}

Blackjacks, Saps, and Billies

In years past, many officers carried, in their back pockets, a blackjack made of stiff leather, a sap or similar weapons. A baton is a brusque stick, like a truncheon.^{Footnote ten} The use of these weapons has generated controversy in recent years.

STRENGTHS

They are readily concealable weapons, of depression cost.
They are easily carried, and are lightweight.

WEAKNESSES

They are besides brusk to be an effective weapon.
They have precipitous edges.
Many saps take loops, which constrict an officer's hands.
Because of the flexible nature of the blueprint, they fail to generate plenty stupor waves to be effective.
They tend to be used with facial/head blows, with the same kind of trauma associated with flashlight injuries (run into above).

LITIGATION EXAMPLES

A federal court in Washington refused to dismiss a suit confronting the master of the D.C. Police force Dept. by an injured man for allowing officers to acquit blackjacks without acceptable preparation. ^{Footnote 11}
A Connecticut man was awarded $227,500 for head injuries caused past an officeholder-inflicted blow with a pocket-size stick; $100,000 was in castigating damages against the city for the negligent failure to provide adequate training. ^{Footnote 12}

The Baton

The typical baton is a round stick of various lengths, and is made of hardwood, aluminum or plastic composite materials.

STRENGTHS

Information technology is a lightweight weapon, and cheap.
The public is accustomed to seeing law officers and security guards routinely carry them.
Information technology has greater accomplish than blackjacks, brusque billies or flashlights; it has greater utility and flexibility equally an impact weapon.
A accident with a billy can immobilize a combative person; it can disarm him if he is carrying an offensive weapon.
Competent training is available from a multitude of public and private trainers.
The baton can exist used as a "come-forth" device in some situations.
A baton can exist used in a non-offensive blocking manner, to ward off blows or to push button back an assaulter.
Manufacturers recommend their products as impact weapons.

WEAKNESSES

They are cumbersome, and therefore, are oft left in the car.
They are non concealable, and are not well suited for plainclothes officers.
They are often in the way when an officer is running.
They can be lost if they autumn from a belt ring, and create a adventure.
It is difficult or incommunicable to avoid caput strikes in all cases, specially in combat situations. Although intensive grooming minimizes this take a chance, information technology cannot entirely eliminate it. Paralysis or death may upshot, even days later, caused by subdural or bilateral hematoma.
Facial strikes often cause lacerations and substantial claret loss. This impairs the department's public image, when citizens notice claret-splattered injuries on Idiot box news programs, or at the scene of arrest, or while visiting a infirmary emergency room.
Departments must periodically retrain officers to maintain billy proficiency.

LITIGATION EXAMPLES

An Illinois man accepted a $127,000 settlement for a skull fracture caused by a billy strike received during a tavern brawl , with police officers. ^{Footnote thirteen}
A Michigan man received $35,000 inpunitive damages, $5,000 for mental ache and $five,000 for pain and suffering. Officers struck him in the groin and on his back when he assumed a "fighting opinion." ^{Footnote xiv}
4 California residents received $43,000 from officers who broke upwardly a loud party using batons, causing a fractured vertebra and a broken wrist. ^{Footnote fifteen}

The 'Come-along' Hold

Although some agencies train officers in (and some manufacturers advocate) the use of the baton equally a "come-along" device, substantial field experience indicates that officers rarely apply their batons for that purpose. While trainers are able to demonstrate the use of batons for hurting-compliance purposes in a sterile classroom setting, there are marked differences betwixt a static demonstration and the dynamics of a hostile field confrontation. Specifically, officers ofttimes state they are unable to get a disobedient or resisting person to stand nevertheless long enough to properly apply a baton come-along hold.

A cautionary note is in social club concerning the training of officers in the use of a baton for come-along holds. In at least 1 case, a police officeholder (who was a certified baton trainer) testified in a personal injury accommodate that information technology was negligent for an officer to utilize a side-handle baton as an impact weapon, without first attempting to apply come up-along holds with the baton. Another expert witness, who specializes in use-of-force preparation, testified that it was proper for the defendent officeholder to initially resort to the utilise of his billy as an bear on weapon, without first attempting compliance with baton-assisted come up-along holds. Fortunately, the jury agreed with the 2d witness, and plant no liability against the officeholder or his employing municipality ^{Footnote 16}

Should officers exist trained in the use of a billy for come-along holds? If the section provides such training, only officers routinely avoid using the technique, this behavior volition be criticized by the plaintiff's lawyer. Opposing counsel volition suggest that since officers were and are presently trained in the use of batons for come-along holds, it was negligence not to utilize these holds before employing the baton as an impact weapon.

Thus, a good argument tin be made for Non TRAINING officers in the apply of billy-assisted come-along holds, if batons are not routinely used for such purposes in field confrontations. Every bit was previously mentioned, many officers avoid using their batons for comealong holds, because the dynamics of a hostile confrontation get in hard, if not incommunicable, to successfully employ these holds to a resisting person. Moreover, many trainers believe that hand-applied pain compliance techniques are tactically superior to baton-practical come up-along techniques.

The Baton Design Controversy

In 1974 the traditional straight billy was optionally modified by adding a side handle. The leading manufacturer of side-handle batons publishes training fabric, and as well trains and certifies instructors.^{Footnote 17} Still, many professional trainers continue to prefer the traditional "straight baton.."^{Footnote 18} Aside from the potential use of a baton for come-along holds, both batons are effective weapons.

Those trainers who prefer the side-handle baton believe it:

generates more ability,
is easier to command,
is more versatile, and
is less likely to be seized by an opponent.

Those trainers and officers who prefer the straight baton believe that it:

generates greater fluid daze waves (which inflict more trauma but cause less harm to tissue)
is superior when used in confined locations,
is easier, quicker and more economical to train officers to a satisfactory level of competency,
is no more than likely to upshot in unintended head strikes than the side-handle billy,
has a shorter recovery time (for additional strikes), and
is more effective when used by shorter and smaller officers, particularly the new small-diameter lightweight models.

An expandable model of the straight baton is bachelor, and is particularly suitable for plainclothes and special duty officers. An all-metallic tokushu keibo collapsible/extendable billy has been in apply past some Japanese police officers since 1966, and is currently issued to members of the Secret Service and U.S. Capitol Law. Japanese experience indicates the weapon is more effective than the wooden baton and causes less bodily harm.

NECK RESTRAINTS

Many neck holds used by officers trace their origin to sport judo. The most traditional restraint is the arm bar which applies pressure with the forearm beyond the front of the neck. Because this technique cuts off the victim'south air supply, it has been widely rejected by law trainers. Every bit with a drowning swimmer, the procedure sometimes precipitates resistance as the person fights for air.

The carotid restraint is taught by many law enforcement agencies. It involves application of the forearm to ane side of the neck, and the bicep surface area of the arm to the opposite side of the neck. The crux of the elbow is positioned at the front of the throat, with particular care and so as not to apply pressure level to the esophagus.

The (Kansas Urban center) lateral vascular cervix restraint is distinctive, in that three levels of control are present. Unlike the carotid restraint which produces unconciousness, this method emphasizes capturing an arrestee'south balance, and the application of pressure in an escalating series of steps. The procedure is likewise characterized by a more dynamic "pull through" application method, than the fixed compression technique of the carotid restraint.

STRENGTHS

Neck restraints are effective, regardless of the size of the officer relative to the person to be controlled.
Unlike batons, the procedure does not require a lot of room for striking distance; it is possible to employ grappling procedures and neck restraint in shut contact, in narrow or cluttered premises.
Neck restraints are an attempt to provide "humane" ways of controlling combative persons without the necessity of striking them, thus minimizing the hazard of broken basic, lacerations and other impact-related trauma.

WEAKNESSES

Neck restraints, if applied improperly, have caused expiry or paralysis.
Due to the dynamics of a violent struggle, it is frequently difficult to correctly apply such methods.
Several instances of "unexplained" expiry have followed purportedly proper application of the technique, unaccompanied past whatever discoverable physical injuries. This phenomena, known as "custody death syndrome," is not fully understood, and inquiry is still ongoing.
Perpetual and time-consuming training is needed to maintain minimum levels of proficiency.
During litigation, information technology is difficult to precisely explain to a jury the physiological furnishings of neck restraint procedures, due to an inadequate base of undisputed medical evidence. Even within the medical community, there are disagreements regarding the mechanism that causes unconciousness.
Information technology is difficult for an officer to monitor and control the amount of force per unit area applied during the process.
In one case the restraint has been practical, there is a need to closely monitor the arrestee. This may be impractical when the individual is hooked into a detention facility operated by another bureau.

LITIGATION EXAMPLES

A Chicago family accepted a $500,000 settlement for the expiry of a man who died from a bar-arm concur. The city offered the settlement despite the fact it did non authorize the hold and instead teaches the carotid restraint method. ^{Footnote 19}
Challenge a bruise and humiliation, an off-duty California sheriffs deputy received $13,360 later being choked by urban center constabulary officers who did non know he was a peace officer and believed him to be armed. ^{Footnote 20}
A male homosexual received $250,000 for aberrant brain waves, following a asphyxiate-concord applied past officers who precipitated a confrontation. The officers observed him kissing a male person friend and asked for his ID, which started a exact confrontation, leading to his forcible arrest. ^{Footnote 21}
Responding to a domestic disturbance, D.C. police officers used a billy to utilise pressure to the back of a homo'southward cervix, while he laid confront-down on the flooring -- causing death by asphyxiation. Although PCP, marijuana and hashish were found in his system, the jury awarded $950,000 to his estate, widow and daughter.^{Footnote 22}

CHEMICAL AGENTS

Several sprays and gases have been on the market for many years, and are marketed under various trade names. In some states, aerosol tear gas is purchasable by whatsoever citizen, and may be lawfully carried. Some states restrict sales and possession to citizens who have taken a four or eight hour training course

STRENGTHS

Tear gas cannisters are inexpensive.
They are lightweight, and easily carried and concealed. They can be used past uniform and plainclothes officers.
Sprays practice not crave extensive training.
No physical contact is needed.

WEAKNESSES

Chemical agents are not constructive on many individuals, especially the mentally disturbed, those who are intoxicated, and persons nether the influence of certain drugs.
Some individuals may get more combative when they experience the discomfort associated with chemical irritants.
There is a time lag between application and upshot; they may not stop ambitious behavior rapidly enough.
A person with a knife or blunt musical instrument who has impaired vision from the spray may lash out in an indiscriminate fashion.
Some individuals who suffer from pre-existing respiratory problems may experience serious medical problems.
The sprays can seriously irritate and harm i'due south eyes, unless the eyes are thoroughly washed.
Wind direction tin cause the officer to be inadvertently affected by the spray, and make him vulnerable to a potentially fatal set on.
Officers may object to transporting prisoners who accept article of clothing saturated with a chemical irritant.

LITIGATION EXAMPLES

A farmer who was function of an organized farm protestation in Washington drove his tractor on a sidewalk. D.C. Police officers threw a tear gas capsule inside, which acquired permanent vision loss in one middle. The jury awarded him $400,000. ^{Footnote 23}
A federal court in Virginia upheld the utilize of tear gas on a prison inmate who was vandalizing his cell. The procedure minimized potential resistance to corrections officers who subdued him.^{Footnote 24}

Electrical WEAPONS

Contempo technology has allowed the development of small-scale batteries and improved discharge units. Typically, such devices discharge a high voltage spark (50,000 volts) at very low amperage (0.iii joules). One such hand-held device is pressed against the combatant, who is quickly downed. Another device (the Taser®) fires pocket-size darts, connected to wires, accomplishing the aforementioned objective at a safer, non-contact distance.

STRENGTHS

These devices are hands carried. They are lightweight and affordable.
Extensive preparation is not required.
They may exist more effective on persons under the influence of PCP and other drugs who do not reply to chemical irritants.
They are especially useful for controlling not-criminal fierce behavior, such as persons who are mentally dumb, or under the influence of mind-altering substances.
It may be unnecessary to resort to firearms to control a person armed with a knife or blunt musical instrument. The Taser® is effective at distances of up to 12-15 feet.
The Los Angeles Police Dept. has extensive experience in using the Taser®, beginning in May of 1980. As of early on 1987, the 50.A.P.D. possessed 550 Taser®due south and had employed the device 775 times.^{Footnote 25}

WEAKNESSES

There are allegations the electrical spark tin can cause scars or burn marks.
Long-term medical studies are non-real. In a California study of 218 persons stunned with the Taser®, three persons died--although these individuals may have perished from the effects of PCP. ^{Footnote 26}
The spark tin can cause a fire hazard if flammables are present. In Ontario, California, a man soaked with gasoline was incinerated when officers shot him with a Taser®.
Hand-held devices have been misused to produce discomfort, when administered by sadistic officers.
Media and constituent representatives accept labelled the devices as "cattle prods," associated with civil rights demonstrations in the Sixties.
The manufacturers of electric weapons may be unwilling to provide testimony or litigation support services.
They may non carry product liability insurance at the time the suit is filed, or the policy may not be effective for the period when the device was manufactured or sold.

LITIGATION EXAMPLES

A federal ceremonious rights suit filed in Atlanta complains a Stun Gun "burned permanent, ugly, disfiguring scars into the flesh of the plaintiff'due south trunk." The suit alleged the "brutal attack" caused hurting, suffering, mental anguish and public humiliation.^{Footnote 27} The cost of defending such suits must be considered before electrical weapons are issued or authorized.
A Federal Courtroom in Nevada ruled for prison officials in a adjust brought by an inmate who objected to the employ of the Taser® to control obstreperous prisoners. The courtroom upheld a prison regulation that allows the use of the Taser® or stun guns when inmates turn down to vacate their cells. The courtroom said the weapons are more suitable than batons, and would inflict less discomfort on others than tear gas. ^{Footnote 28}

RECOMMENDATIONS

Collect and preserve all brochures and other literature published past the manufacturer and distributor for each type or model of weapon purchased.
Create a written memorandum-style record of whatever conversations with sales personnel concerning the merits of their product, its suitability for specified purposes, and any statements made which are intended to alleviate your questions concerning civil liability; attach a copy of the memo to the purchase order for the production.
Insist on receiving a photocopy of the products liability insurance policy issued to the manufacturer and/or benefactor.
Require vendors to provide a list of all old and pending claims and litigation against the production under consideration, including names of legal counsel and the issue or status of each claim.
Ask your legal counsel to consider a third-party claim against the manufacturer and/or distributor of whatsoever product which is the subject of a claim or lawsuit confronting your agency or personnel.
Don't wait for a lawsuit before preparing your defence. The time to line up proficient witnesses in support of a particular weapon or tactic is now. If possible, go written recommendations from any consultants used, and a committment from each consultant that he will announced in court to defend his recommendations, if necessary.
Police force enforcement administrators should unhesitatingly initiate disciplinary action against subordinate officers who bear or use unauthorized weapons (or who apply unauthorized control techniques), even if otherwise appropriate or excusable under the detail circumstances. Disciplinary activeness should fit the crime and eggregiousness of the bear; in some cases, a written reprimand will be sufficient, in others, more severe activeness is warranted. The failure to administer cautionary subject can itself predicate the liability of a law enforcement agency. It volition be easier for plaintiffs counsel to evidence that superior officers knew (or should have known) such weapons or techniques were probable to exist used in the instant case.

CONCLUSIONS

The use of force and weapons by law enforcement officers is one of the most visible and controversial aspects of policing. It is likely to remain so.

A law enforcement agency must carefully choose the various devices and techniques it will qualify for the protection of its officers and the public. In making policy decisions in this area, an agency should consider existing court decisions and litigation trends.

No matter what policies an agency adopts, the use of force by officers should be advisedly monitored on a continuing basis. An agency should not hesitate to alter its policies when circumstances and so indicate.

In our efforts to continually assistance the police force enforcement customs, AELE welcomes comments, information and suggestions. Nosotros are especially interested in lawsuits, verdicts and testimony by proficient witnesses.

********

This certificate was co-authored by an experienced police defensive-tactics instructor and an attorney who specializes in law enforcement liability research. It was formally reviewed by two exterior legal counsel; one is an instructor at a nationally prominent university-based police grooming eye, and the other serves as chief legal counsel to a large police agency. It was also reviewed by a trial lawyer who has more than than 20 years experience in defending police apply-of-forcefulness lawsuits.

This paper does non attempt to raise all of the strengths or weaknesses of whatsoever not-lethal weapon or control tactic. The litigation examples merely illustrate the kinds of civil actions that have been brought confronting constabulary enforcement agencies and personnel; they are non intended to discourage the proper use of any accepted defense or control tactic, method or commercially marketed product. AELE has provided this summary as a starting point for the ongoing discussion and debate over the weapons, techniques and tactics described herein.

FOOTNOTES

The Confrontational Continuum model developed past Kevin Parsons and Associates was copyrighted in 1980. Dr. Parsons is a nationally prominent police training provider, and has testified as an adept witness in more than than fifty lawsuits alleging excessive strength by law enforcement personnel.
IACP 1987 Annual Law Enforcement Survey: Executive Summary, 55 (I) The Police Primary 38 [at 39] (January, 1988); Gaithersburg, MD.
Statement of George Hoffman, President of L.A. Screw Products Police Equipment Partitioning in a alphabetic character to the editor of Police Production News, replying to an article in the November, 1980 issue entitled Dueling Flashlights.
Wyche v. City of Los Angeles, 103 L.E. Liab. Rptr. (AELE) 4, Super. Ct., Los Angeles, Co. Cal. (1980); the city dropped an appeal and paid the plaintiff.
Steinnagle v. Frazer, 124 L.East. Liab. Rptr. (AELE) three, Cm. Pls. Ct., Bucks Co., Pa. (1/8/83).
Wellington v. Daniels, 125 L.E. Liab. Rptr. (AELE) 3, modif. 127 L.E. Liab. Rptr. (AELE)four, Civ. No. 81-208-NN (E. D. Va. 1982); the city was dismissed from the suit on a motion for judgment N.O.Five. because the municipality did non provide the flashlight and at that place was no testify the urban center allowed the officer to carry it. A single instance of excessive force does not create a "policy or exercise" under Monell 5. Dept. of Social Services, 436 U.S. 658 (1978). See Metropolis of Oklahoma Metropolis five. Tuttle, 105 S. Ct. 2427 (1985).
Melina 5. Chaplin, 112 L.Eastward. Liab. Rptr. (AELE) five, Dist. Ct., Hennepin Co. Minn. (1981).
Arnold five. Pydyn, 159 L.E. Liab. Rptr. (AELE) five, U.Southward. Dist. Ct. (E.D. Mich. 11/24/85).
People v. R.C S., Los Angeles County Superior Court No. A-781184 ( 1987),
For a legal definition of a billy or blackjack, come across Annotation, "What constitutes a 'bludgeon, 'blackjack,' or 'billy' within meaning of criminal possession statute," eleven ALR 4th 1272 (1982).
Hardeman five. Clark, 593 F. Supp. 1285 (D.D.C. 1984). 1
Ieva v. Stamford, 110 L.Due east. Liab. Rptr. (AELE) eleven, U.S. Dist Ct. (D. Conn. 1981).
Van Ham v. City of Aurora, 131 L.E. Liab. Rptr. (AELE) 3, U.S. Dist. Ct. (N.D. I11. 1983}.
Shulick v. Floyd, 113 50.E. Liab. Rptr. (AELE) iv, U.South. Dist. Ct. (W.D. Mich. 1981).
Lopez 5. Grant, 111 50.Eastward. Liab. Rptr. (AELE) 4, Super. Ct. Santa Clara Co. Cal. (1981).
Fronk v. Meager, No. Dak. Supreme Ct. No. 870085, -- Northward.W. 2d -(N.D. Dec 29, 1987).
See The Monadnook PR-24 "Prosecutor", a training manual by Richard R. Starrett, Monadhock Lifetime Products. Fitzwilliam NH. Lib. Cong. True cat. No. 76-6768 (1976).
See The Koga Method: Police Baton Techniques, past Robert K. Koga and John G. Nelson, Glencoe Press/Macmillan Co., Beverly Hills CA, Lib. Cong. True cat. No. 68-19201 (1968).
Nethery v. City of Chicago, 136 L.E. Liab. Rptr. (AELE) 3, Cir. Ct., Cook Co. Ilk No. 81-C 2911 (1983).
Stevens v. City of Los Angeles, I11 L.East. Liab. Rptr. (AELE) 12, Super. Ct., Los Angeles Co. Cal. (1981).
Barlow 5. City of Long Beach, 145 Fifty.E. Liab. Rptr. (AELE) three, Super Ct., Los Angeles Co. Cal. (1984).
Utley v. Dist. of Columbia, D.C. Super. Ct. No. 1558-83, 29 ATLA Police Rep. 32 (1986).
District of Columbia five. Colston, 468 A. second 954 (D.C. App. 1983).
Greear v. Loving, 391 F. Supp. 1269 (West.D. Va. 1975).
"Los Angeles P.D. finds Taser® stunningly effective," Torrance Daily Breeze, reprinted in PORAC News (Feb. 1987), p. thirteen
"Report Finds Safer Than Guns: King Hospital Doctors Compare Outcomes of Victims," Los Angeles Times, Jan. sixteen, 1986), Part V, p. 22.
[Nancy Moore] Smith five. [Officer P.L.] Forest et al, U.Due south. Dist. Ct. No. C86-1152A (N.D. Ga., filed 6/19/86).
Michenfelder five. Sumner, 624 F. Supp. 457 fat 463-4] (D. Nev. 1985).

FIGURE ane:

Research funding for this certificate was generously provided by MARKEL SERVICE, INC. Law Enforcement and Public Officials Liability Insurance Underwriters and Brokers

Copyright by Americans for Effective Constabulary Enforcement, Inc. Permission to reproduce or republish, but not for profit is granted provided appropriate credit is given AELE.

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