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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