What is the test for an excessive force claim against a police officer?

"A peace officer is not 'engaged in the performance of his or her duties' within the meaning of these statutes if he arrests a person unlawfully or uses excessive force in making the arrest." (People v. Delahoussaye (1989) 213 Cal.App.3d 1, 7.) Excessive force claims are analyzed under the " 'reasonableness' standard" of the Fourth Amendment. (Graham v. Connor (1989) 490 U.S. 386, 395.) "[T]he question is whether the officers' actions are 'objectively reasonable' in light of the facts and circumstances confronting them, without regard to their underlying intent or motivation." (Id. at p. 397.) Factors to be considered include "the severity of the crime at issue, whether the suspect poses an immediate threat to the safety of the officers or others, and whether he is actively resisting arrest or attempting to evade arrest by flight." (Id. at p. 396.)

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