What is the test for an excessive force claim against a correctional officer-bystander?

MultiRegion, United States of America

The following excerpt is from Holt v. Nicholas, Case No.: 1:09-cv-00800-AWI-SAB (PC) (E.D. Cal. 2015):

In order to state an excessive force claim against correctional officer-bystanders, a plaintiff must allege circumstances demonstrating that these officers had an opportunity to intervene and prevent or curtail the violation, but failed to do. Robins v. Meecham, 60 F.3d 1436, 1442 (9th Cir. 1995). In other words, the plaintiff must show that the defendant-bystander had enough time to observe what was happening and to intervene and stop it. Id. A defendant is liable for failing to

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