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Module 12 of 30

Use of force, de-escalation and deadly force

Objective reasonableness and the totality of the circumstances, SAPC ch. 9 justification, deadly force and vehicles, qualified immunity, Tasers, chemical agents, impact munitions and dogs, people in crisis, prone restraint, force in custody, and the duties to intervene, render aid and report.

Required for Class A Class B Class C Class D Class E Class F

The exam draws 30 questions from a bank of 56. You have 45 minutes, and you need 80% to pass. Questions apply the law to situations. To prepare, read this guide alongside the cited sections of the San Andreas codes, the 2026 Law Enforcement Reform Package and the federal authorities below. The U.S. Constitution binds every San Andreas officer. Supreme Court decisions are binding; federal circuit decisions are accepted authority, and where circuits differ the academy teaches the rule that protects rights more.

Force used to stop or arrest someone is a Fourth Amendment seizure, and it is judged by objective reasonableness from the perspective of a reasonable officer on the scene, not with the 20/20 vision of hindsight (Graham v. Connor). The court weighs the severity of the crime, whether the person poses an immediate threat to the safety of officers or others, and whether he is actively resisting or trying to evade arrest by flight. Your good or bad intentions do not decide it. Applying physical force to the body with intent to restrain is a seizure even if the person escapes (Torres v. Madrid), so a Taser probe or a bullet that strikes a fleeing person must meet the same standard. Excessive-force claims look at the totality of the circumstances, including events before the moment of threat; courts may not confine review to the final seconds (Barnes v. Felix). That means your approach, positioning, commands and earlier choices are part of the record a court will weigh. Barnes does not say an earlier mistake automatically makes later force unlawful; it says the whole sequence counts.

San Andreas law states the same idea in its own words. A peace officer, or a person acting at the officer's direction, is justified in using force when and to the degree the officer reasonably believes it immediately necessary to make or assist a lawful arrest or search, to prevent escape, or to defend against resistance, provided the officer first identifies himself unless his identity is reasonably known (SAPC §9.09). Deadly force is justified only where the officer reasonably believes it necessary to prevent death or serious bodily injury to the officer or another, or to prevent the escape of a person who poses such a threat (§9.09). Serious bodily injury means injury that creates a substantial risk of death or causes death, serious permanent disfigurement or protracted loss or impairment of a bodily member or organ (§1.41). Justification is a defense, not a power to punish: force used to get even, to compel answers, or because someone is rude has no place in §9.09. A person may not resist a lawful arrest or search with force, even if he believes it unlawful, where the officer uses no greater force than necessary; the narrow exception covers only clearly excessive and unlawful deadly force (§9.16).

Deadly force against a fleeing suspect is governed by Tennessee v. Garner: it may not be used unless the officer has probable cause that the suspect poses a significant threat of death or serious physical injury, and a warning must be given where feasible. A burglar running from a house, an unarmed car thief, or a man who just passed a bad check may not be shot to stop his flight. A man who has just shot a clerk and is running with the gun toward a crowded bus stop may be. Warnings matter beyond deadly force too: warnings should be given before less-lethal force when feasible (Deorle v. Rutherford), and the availability of warnings and less intrusive alternatives bears on reasonableness (Glenn v. Washington County). The academy does not teach warning shots: a round fired into the air is aimed at no threat, so §9.09 does not justify it, and discharging a firearm recklessly where people are likely to be endangered is Reckless Discharge of a Firearm (SAPC §46.28). Every round you fire is aimed at a threat you can articulate, and you are accountable for where it goes.

Vehicles are where officers most often get force wrong. Ending a high-speed chase that threatened innocent lives by ramming the fleeing car was reasonable (Scott v. Harris). Firing to end a dangerous car chase was not clearly excessive, and officers need not stop shooting until the threat has ended (Plumhoff v. Rickard). But when the threat ends, the justification ends: shooting at a driver after the car has passed and no longer threatens the officer can be unreasonable (Abraham v. Raso), and firing at a car moving away, after any threat has passed, can be excessive deadly force (Lytle v. Bexar County). Do not step into the path of a moving car and then shoot because you are in its path; under Barnes v. Felix the whole sequence, including how you got there, is reviewed. A roadblock that stops a fleeing car is a seizure and must be reasonable (Brower v. County of Inyo). A death in a high-speed chase violates substantive due process only if the officer intended harm unrelated to arrest (County of Sacramento v. Lewis), but that narrow constitutional rule does not make a reckless pursuit good policy or lawful under agency rules.

Learn the difference between 'lawful' and 'immune'. Officials have qualified immunity unless they violate clearly established rights a reasonable person would have known (Harlow v. Fitzgerald). Several force cases officers quote were decided on that ground and do not approve the tactic. Shooting a driver fleeing in a car was not clearly established as unlawful at the time, and the test turns on the specific danger (Brosseau v. Haugen). Briefly placing a knee on the back of a prone, armed suspect while removing a knife was not clearly established as excessive (Rivas-Villegas v. Cortesluna). Officers who reentered a room of an armed, mentally ill woman were entitled to qualified immunity because the reentry was not clearly established as unlawful (City and County of San Francisco v. Sheehan). None of these says the force was a good idea, and immunity can disappear as later cases clarify the law. Officials can have fair warning that conduct is unlawful even in novel circumstances; an identical prior case is not required (Hope v. Pelzer). At summary judgment, courts view disputed facts in the light most favorable to the person shot (Tolan v. Cotton), which is one more reason your report and camera footage must be accurate and complete.

Conducted energy weapons are not a compliance tool. A Taser in dart mode is an intermediate, significant use of force; using it on an unarmed traffic offender who was not an immediate threat was excessive (Bryan v. MacPherson). Sitting en banc, the Ninth Circuit held that tasing a pregnant driver for refusing to sign a ticket, and tasing a woman who was trying to calm a domestic disturbance, was excessive (Mattos v. Agarano). Tasing a mentally ill man who was passively resisting by holding a post, and who posed little risk, was excessive; tasers are for immediate safety threats (Estate of Armstrong v. Village of Pinehurst). Tasing a mentally ill person who was non-compliant but not posing an immediate threat can be excessive (Gray v. Cummings). The common thread is that non-compliance, refusal and passive resistance are not the same as an immediate threat. When someone is merely refusing, slow down, use time, distance and communication, bring enough officers to control him by hand if needed, and give a warning before any device is used where feasible.

Chemical agents and impact munitions follow the same logic. Firing a beanbag round without warning at an emotionally disturbed, unarmed man who posed no immediate threat was excessive, and warnings should be given when feasible (Deorle v. Rutherford). Applying pepper spray to the eyes of nonviolent, passively resisting protesters who could be removed by other means was excessive (Headwaters Forest Defense v. County of Humboldt). Leaving pepper spray on a compliant, restrained arrestee and refusing decontamination can be excessive (LaLonde v. County of Riverside); once the person is under control, decontaminate with water and fresh air as soon as it is safe and get medical help if he struggles to breathe. Continued force, including a police dog and pepper spray, on a man who was not actively resisting can be excessive (Smith v. City of Hemet), and continuing pepper spray on a prone, restrained, unresisting person was part of the excessive force in Champion v. Outlook Nashville. Force that was justified at second one may not be justified at second twenty: reassess after every application.

Police dogs are force. Using a police dog to find and seize a hiding suspect is force that must be justified under Graham (Chew v. Gates): the handler must weigh the crime, the threat and the resistance before releasing the dog, and, as with other force, give a warning where feasible so the suspect can surrender (Deorle v. Rutherford), and call the dog off as soon as the suspect is under control. Ordering a police dog to attack a suspect who was complying and lying on the ground was excessive (Priester v. City of Riviera Beach). Smith v. City of Hemet reached the same result where a dog and pepper spray were used on a man who was not actively resisting. A canine team may deploy only in the discipline in which the handler and dog are certified together (Act V §5.04); a narcotics-detection dog is not an apprehension dog. Hurting a police service animal is its own crime (SAPC §38.39), but that does not change what the dog may be used for.

People in crisis need a different approach, not less force by accident or more force by impatience. A person's mental state, the availability of less intrusive alternatives and warnings bear on reasonableness, and a threat to oneself is not the same as a threat to others (Glenn v. Washington County). A man holding a knife to his own throat, far from anyone else, is in danger, but he is not by that fact an immediate threat to officers. De-escalation means slowing the incident down: create distance and cover, contain rather than close in, let one officer talk in a calm voice, listen, and bring in crisis-trained help where you can. Do not rush in because waiting is uncomfortable. Non-deadly force is justified when reasonably believed immediately necessary to prevent a person from committing suicide or inflicting serious bodily injury on himself (SAPC §9.07), and an emergency mental-health detention is protective custody, not punishment. Sheehan's grant of qualified immunity does not mean that reentering a room on an armed person in crisis is a tactic to copy.

Restraint is where people die quietly. Holding a restrained person prone with pressure on the back must be judged with attention to known risks of positional asphyxia and how long the pressure lasted (Lombardo v. City of St. Louis). Kneeling on the back and neck of a handcuffed, prone, compliant mentally ill man, causing compression asphyxia, was excessive (Drummond v. City of Anaheim). Putting weight on the back of a prone, restrained, unresisting person, and continuing pepper spray, was excessive (Champion v. Outlook Nashville). Holding pressure on the upper back of a restrained, prone person after the need for it ended could be excessive given the known risk of asphyxia (Weigel v. Broad). Hog-tying a person whose diminished capacity is apparent is excessive force (Cruz v. City of Laramie). Rivas-Villegas allowed only a brief knee on an armed suspect while a knife was removed; it is not permission for sustained weight. The practice is simple: get handcuffs on, get weight off, roll the person onto his side or sit him up, watch his breathing and colour, and take 'I can't breathe' seriously every time.

Inside a jail or prison the constitutional source changes, but the duty to use only necessary force does not. Force against a pretrial detainee is excessive if it is objectively unreasonable; the officer's state of mind is not required (Kingsley v. Hendrickson), so 'I did not mean to punish him' is no defense to unreasonable force. Force against convicted prisoners in a prison disturbance is judged by whether it was a good-faith effort to restore order or applied maliciously and sadistically to cause harm (Whitley v. Albers), and malicious force against a prisoner violates the Eighth Amendment even without serious injury (Hudson v. McMillian). Class E officers use force as correctional law allows, within their lawful duties (Act VIII §8.06). Officers who beat a prisoner to death under color of law may be prosecuted for willfully depriving him of constitutional rights (Screws v. United States), and the same conduct is a crime in San Andreas.

Force has legal consequences for the officer. Force beyond what is reasonably necessary that causes bodily injury is Police Misconduct, Excessive Use of Force (SAPC §39.01), a Class A Misdemeanor, or a 3rd Degree Felony with serious bodily injury. Willfully depriving a person of a constitutional right under color of law, including by excessive force, is §38.82, graded up to a 1st Degree Felony if death results; civil liability follows under 42 U.S.C. § 1983 and federal prosecution under 18 U.S.C. § 242. An officer who sees a colleague use clearly excessive force must intervene when there is a realistic opportunity, by word or by physically stepping in, and must report it; an order from a supervisor never makes unlawful force lawful. Disabling or covering a body-worn camera to prevent recording is SAPC §38.101. A knowingly false report about force is §38.81, a 3rd Degree Felony.

When the force stops, your duties begin. Once the scene is safe, render aid within your training and summon medical help without delay, and keep monitoring anyone who was struck, shocked, sprayed, bitten or restrained. A person you have restrained is in your custody and depends on you; DeShaney v. Winnebago County recognizes that custody creates duties the state does not otherwise owe. Preserve the scene and the camera footage. Every officer who used or witnessed reportable force documents it promptly, completely and in his own words: what he saw and heard, what the person was doing, what force was used, for how long, and when it stopped. Do not copy another officer's narrative, and do not adjust your account to match the video; if the video shows something you did not perceive, say so plainly. A filed report is corrected only by a dated supplement; altering or removing the original record can be Tampering with a Government Record (§39.02). Honest, specific reporting is what lets a reviewer see a reasonable decision as reasonable.

Constitution and case law

The federal authorities this module's questions rely on, and the rule the academy takes from each.

U.S. Const. amend. IV
No unreasonable searches and seizures; warrants only on probable cause, supported by oath, particularly describing the place and things.
U.S. Const. amend. VIII
No excessive bail or fines and no cruel and unusual punishment; governs force and medical care for convicted prisoners.
U.S. Const. amend. XIV, § 1
Due process and equal protection bind the states and every state officer; incorporates the Bill of Rights against the states.
42 U.S.C. § 1983
Civil liability for anyone who, under color of state law, deprives a person of a federal right.
18 U.S.C. § 242
Federal crime to willfully deprive a person of a constitutional right under color of law.
Torres v. Madrid, 592 U.S. 306 (2021)
Applying physical force to the body with intent to restrain is a seizure even if the person escapes.
Tennessee v. Garner, 471 U.S. 1 (1985)
Deadly force may not be used to stop a fleeing suspect unless the officer has probable cause the suspect poses a significant threat of death or serious physical injury, with a warning where feasible.
Graham v. Connor, 490 U.S. 386 (1989)
Force in an arrest or stop is judged by objective reasonableness from the perspective of a reasonable officer on the scene, weighing the severity of the crime, the immediate threat and active resistance or flight.
Barnes v. Felix, 605 U.S. ___ (2025)
Excessive-force claims look at the totality of the circumstances, including events before the moment of threat; courts may not confine review to the final seconds.
Scott v. Harris, 550 U.S. 372 (2007)
Ending a high-speed chase that threatened innocent lives by ramming the fleeing car was reasonable.
Plumhoff v. Rickard, 572 U.S. 765 (2014)
Firing to end a dangerous car chase was not clearly excessive; officers need not stop shooting until the threat has ended.
Brosseau v. Haugen, 543 U.S. 194 (2004)
Shooting a driver fleeing in a car was not clearly established as unlawful at the time; the test turns on the specific danger.
Brower v. County of Inyo, 489 U.S. 593 (1989)
A roadblock that stops a fleeing car is a seizure and must be reasonable.
County of Sacramento v. Lewis, 523 U.S. 833 (1998)
A death in a high-speed chase violates substantive due process only if the officer intended harm unrelated to arrest.
Kingsley v. Hendrickson, 576 U.S. 389 (2015)
Force against a pretrial detainee is excessive if objectively unreasonable; the officer's state of mind is not required.
Lombardo v. City of St. Louis, 594 U.S. 464 (2021)
Holding a restrained person prone with pressure on the back must be judged with attention to known risks of positional asphyxia and how long the pressure lasted.
Tolan v. Cotton, 572 U.S. 650 (2014)
At summary judgment courts must view disputed facts in the light most favorable to the person shot.
Rivas-Villegas v. Cortesluna, 595 U.S. 1 (2021)
Briefly placing a knee on the back of a prone, armed suspect while removing a knife was not clearly established as excessive.
City and County of San Francisco v. Sheehan, 575 U.S. 600 (2015)
Officers who reentered a room of an armed, mentally ill woman were entitled to qualified immunity; the reentry was not clearly established as unlawful.
Harlow v. Fitzgerald, 457 U.S. 800 (1982)
Officials have qualified immunity unless they violate clearly established rights a reasonable person would have known.
Hope v. Pelzer, 536 U.S. 730 (2002)
Officials can have fair warning that conduct is unlawful even in novel factual circumstances; an identical prior case is not required.
DeShaney v. Winnebago County, 489 U.S. 189 (1989)
Due process generally imposes no duty to protect a person from private violence unless the state has them in custody.
Whitley v. Albers, 475 U.S. 312 (1986)
Force in a prison disturbance is judged by whether it was a good-faith effort to restore order or applied maliciously and sadistically to cause harm.
Hudson v. McMillian, 503 U.S. 1 (1992)
Malicious force against a prisoner violates the Eighth Amendment even without serious injury.
Deorle v. Rutherford, 272 F.3d 1272 (9th Cir. 2001)
Firing a beanbag round without warning at an emotionally disturbed, unarmed man who posed no immediate threat was excessive; warnings should be given when feasible.
Bryan v. MacPherson, 630 F.3d 805 (9th Cir. 2010)
A taser in dart mode is an intermediate, significant use of force; using it on an unarmed traffic offender who was not an immediate threat was excessive.
Mattos v. Agarano, 661 F.3d 433 (9th Cir. 2011)
En banc: tasing a pregnant driver for refusing to sign a ticket, and tasing a woman trying to calm a domestic disturbance, was excessive.
Glenn v. Washington County, 673 F.3d 864 (9th Cir. 2011)
A person's mental state, the availability of less intrusive alternatives and warnings bear on reasonableness; a threat to oneself is not the same as a threat to others.
Estate of Armstrong v. Village of Pinehurst, 810 F.3d 892 (4th Cir. 2016)
Tasing a mentally ill man who was passively resisting by holding a post, and posed little risk, was excessive; tasers are for immediate safety threats.
Smith v. City of Hemet, 394 F.3d 689 (9th Cir. 2005)
En banc: continued force, including a police dog and pepper spray, on a man who was not actively resisting can be excessive.
Drummond v. City of Anaheim, 343 F.3d 1052 (9th Cir. 2003)
Kneeling on the back and neck of a handcuffed, prone, compliant mentally ill man, causing compression asphyxia, was excessive.
Champion v. Outlook Nashville, Inc., 380 F.3d 893 (6th Cir. 2004)
Putting weight on the back of a prone, restrained, unresisting person, and continuing pepper spray, was excessive.
Weigel v. Broad, 544 F.3d 1143 (10th Cir. 2008)
Holding pressure on the upper back of a restrained, prone person after the need for it ended could be excessive given the known risk of asphyxia.
Cruz v. City of Laramie, 239 F.3d 1183 (10th Cir. 2001)
Hog-tying a person whose diminished capacity is apparent is excessive force.
LaLonde v. County of Riverside, 204 F.3d 947 (9th Cir. 2000)
Leaving pepper spray on a compliant, restrained arrestee and refusing decontamination can be excessive.
Headwaters Forest Defense v. County of Humboldt, 276 F.3d 1125 (9th Cir. 2002)
Applying pepper spray to the eyes of nonviolent, passively resisting protesters who could be removed by other means was excessive.
Gray v. Cummings, 917 F.3d 1 (1st Cir. 2019)
Tasing a mentally ill person who was non-compliant but not posing an immediate threat can be excessive.
Priester v. City of Riviera Beach, 208 F.3d 919 (11th Cir. 2000)
Ordering a police dog to attack a suspect who was complying and lying on the ground was excessive.
Chew v. Gates, 27 F.3d 1432 (9th Cir. 1994)
Using a police dog to find and seize a hiding suspect is force that must be justified under Graham.
Abraham v. Raso, 183 F.3d 279 (3d Cir. 1999)
Deadly force is judged on all the circumstances; shooting at a driver after the car has passed and no longer threatens the officer can be unreasonable.
Lytle v. Bexar County, 560 F.3d 404 (5th Cir. 2009)
Firing at a car moving away, after any threat has passed, can be excessive deadly force.

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