Does the use of a chokehold on a non-resisting person violate the Fourth Amendment?

MultiRegion, United States of America

The following excerpt is from Tuuamalemalo v. Greene, 946 F.3d 471 (9th Cir. 2019):

Our circuit is not alone in reaching this conclusion. There is a robust consensus among the circuits that the use of a chokehold on a non-resisting person violates the Fourth Amendment. See Coley v. Lucas Cty. , 799 F.3d 530, 541 (6th Cir. 2015) ("Chokeholds are objectively unreasonable where an individual is already restrained

[946 F.3d 478]

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