What is the test for excessive force in the context of the Second Amended Complaint?

Second, Plaintiffs allege that the conditions of confinement are constitutionally inadequate, that they are forced to live in squalid conditions that are inhumane and pose a serious health risk. Plaintiffs have a clearly established right not to be exposed to such unsanitary conditions. See Anderson v. County of Kern, 45 F.3d 1310, 1314-15 (9th Cir.1995) (collecting cases in prison context); Youngberg, 457 U.S. at 315-16, 102 S.Ct. 2452 (establishing a right to "personal security" for involuntarily committed persons).¹⁵ Given the allegations in the Second Amended Complaint, Plaintiffs' claims as to the unsanitary and unsafe conditions of confinement cannot be dismissed under Federal Rule of Civil Procedure 12(b)(6).

Plaintiffs also allege several claims of excessive force, i.e., that (a) "red light alarms" are used when Plaintiffs orally refuse to participate in treatment, even if they pose no threat of physical violence; (b) that shackles are used during transportation and during visits with family and friends; and, more generally, (c) that Plaintiffs are subjected to "excessive punishment . . . and excessive use of force and physical restraints." It is well-established that detained persons have a right to be free from excessive force. While excessive force claims by prisoners are reviewed under the Eighth Amendment's malicious and sadistic standard, Hudson v. McMillian, 503 U.S. 1, 112 S.Ct. 995, 117 L.Ed.2d 156 (1992), the more generous Fourteenth Amendment standard applies to those who are civilly confined. As we previously stated:

[449 F.3d 1001]

Jones, 393 F.3d at 933.