The following excerpt is from Gonzalez v. City of Anaheim, 747 F.3d 789 (9th Cir. 2014):
Because an accepted way to restrain a driver who poses dangers to others is through seizure, officers pursuing fleeing drivers may deem themselves duty bound to escalate their response to ensure the felon is apprehended. Scott v. Harris rejected the possibility that police could eliminate the danger from a vehicle flight by giving up the chase because the perpetrator might have been just as likely to respond by continuing to drive recklessly as by slowing down and wiping his brow. And once the pursued vehicle is stopped, it is sometimes necessary for officers to approach with guns drawn to effect arrest. Confrontation with police is the expected result of vehicle flight. It places property and persons at serious risk of injury.
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