California, United States of America
The following excerpt is from People v. Johnson, 231 Cal.App.3d 1, 282 Cal.Rptr. 114 (Cal. App. 1991):
Here, defendant struggled violently with the officers for five minutes. The need for handcuffing during questioning was patently justified by concern for officer safety. "The handcuffs eliminated the possibility of an assault or escape attempt during the questioning, particularly if an arrest became imminent." (United States v. Bautista, supra, 684 F.2d 1286, 1290.)
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