Is handcuffing excessive force in violation of the Fourth Amendment?

In Esmont v. City of New York , 371 F. Supp. 2d 202 (E.D.N.Y. 2005), the United States District Court for the Eastern District of New York concluded that placing handcuffs on an arrestee in a manner that causes injury may "constitute excessive force in violation of the Fourth Amendment." Id. at 215 (citation omitted). And it provided three evidentiary factors for courts to consider in evaluating the reasonableness of a handcuffing: that "(1) the [arrestees] handcuffs were unreasonably tight; (2) the defendants ignored the arrestees pleas that the handcuffs were too tight; and (3) the degree of injury to the [arrestees] wrists." Id . at 215. Following Esmont , evidence of these factors has often been employed by other district courts

[941 F.3d 613]