ALERT is a periodic training guide provided without cost to the law enforcement community. Previous editions have addressed Vehicle Searches and Interrogations and Confessions. In this paper, we look at some of the major use-of-force issues and controversies facing law enforcement personnel. The debate concerning specific tactics of non-lethal weaponry is more than theoretical; the relative merits and criticisms of these have been the subject of extensive litigation, with contradictory views expressed in the classrooms by police trainers and in the courtrooms by opposing expert witnesses.

The Progression of Force

Law enforcement officers are permitted to use the degree of force that is reasonably necessary to accomplish their lawful objectives and to overcome any unlawful resistance. The progression of force can be depicted graphically, such as the Confrontational Continuum developed by Kevin Parsons, Ph.D. and similar models developed by others.Footnote 1 These models describe what have often been vague policies on this subject. Such models are also useful in litigation; they explain to the jury why an officer responded in a particular fashion. They also give the jury a standard by which they can judge whether the use of force was correct. Figure 1 depicts the Parsons Continuum, which is a linear acceleration through a progressive series of steps.

The usual first step is verbal persuasion; the second is manual escort. If unsuccessful or inappropriate, the next step is pain compliance. Usual methods of pain compliance include the wrist lock, arm bar or other "come-along" technique. It is only when mechanical control methods are ineffective (or not appropriate) that the force applied escalates to the use of impact weapons.

The principal police impact weapon is the baton. It is the intermediate step between hand-applied force and the ultimate force of firearms. It should be noted that most police trainers will consider it a poor practice or even negligence not to issue and train officers with a baton (except those few departments whose officers are not armed at all). The alleged negligent act is allowing officers to escalate from hand-holds and pain compliance directly to deadly force, when the application of a greater degree of non-lethal force would likely have accomplished the objective of overcoming resistance.

Certain circumstances may warrant an accelerated reaction using a higher degree of force when initiating a contact with a violent or dangerous person. Combative behavior or the influence of alcohol, drugs or controlled substances (such as PCP) could justify greater force in the initial stages.

How Control Techniques are Measured

On the one side is the likelihood of gaining control of an individual; on the other is the likelihood and extent of injury. In general, techniques which have a high propensity for causing tissue damage, hematoma or clotting and have a low potential for control should be rejected. Conversely, methods or weapons that have a low likelihood of causing injury, but a high potential for control, should be encouraged.

Parenthetically, it should be noted that some trainers have suggested that any device is suitable for use if a training program and certification accompany that weapon. Many court cases have demonstrated the fallacy of that view. While compliance and control training is an absolute necessity, injuries or death may still occur because of the human factors of misapplication, miscalculation, and excessive strength.

The 'But-For' Argument... Failure to Assess Alternatives, Too Hasty a Response?

Often a law enforcement officer is placed in a situation where he must resort to the use of a weapon in defense of himself, fellow officers, or a citizen. If litigation follows the event, an expert may testify that the officer failed, in the initial stages of the contact, to de-escalate or avoid the confrontation, and that the ensuing and predictable injury or death could have been prevented by:

In this way, superior officers (such as the chief, sheriff, or director of training) may be held personally liable for a tragic event, even though they did not directly authorrize the officer's action or conduct, and were not present at the time it occurred. Such is the nature of the tort of administrative negligence.


In 1987 the International Association of Chiefs of Police (IACP) surveyed 2,914 police agencies, most of which were in the U.S.Footnote 2 A series of questions related to the types of weapons issued or permitted; the percentage of agencies that had approved each weapon mentioned is indicated below:

AELE does not approve or disapprove of the use of any of these per se. We have attempted to list some of the major strengths and weaknesses of each of these, to assist the law enforcement community in decision-making in this controversial area.

The Flashlight


  1. It is usually readily available, especially at night; it is considered standard equipment.
  2. It does not give the outward appearance of an offensive weapon.
  3. It can be used with minimal reaction time, if held in one's hand.
  4. The light can temporarily disorient or impair the sight of an opponent.
  5. It is "effective" as an impact weapon, in that it will deliver a heavy blow.


  1. Manufacturers are reluctant to approve or endorse the use of their flashlights as impact weapons. One manufacturer stated that "... it would be irresponsible to use a flashlight for striking, jabbing or other offensive moves... Our company has never advocated the use of the flashlight as a weapon, nor to our knowledge has any responsible flashlight manufacturer." FOOTNOTE 3
  2. Flashlights have too short a reach for effective use as a tactical weapon.
  3. Flashlights provide a slower response than batons; the recovery time is not rapid enough.
  4. Flashlights have sharp edges that will cut a person.
  5. Multi-cell lights are very heavy; a blow to the head can be fatal or cause permanent paralysis.
  6. An officer who carries a weighted flashlight and a baton will be reluctant to drop his light and pull the baton. If the officer does discard the light, it could be used as a weapon against him. He may therefore strike the offender with the light (which is already in his hand) instead of using the baton, as he was trained.


  1. A Los Angeles man recovered a jury verdict of $1,250,000 from a flashlight blow to his head during a scuffle, following a routine traffic stop for having a loud muffler.Footnote 4
  2. A Pennsylvania woman and her mother recovered $175,000 for dizzy spells resulting from a flashlight blow.Footnote 5
  3. A Virginia man received a judgment of $1,500,000 to compensate him for speech impairment and paralysis, following a flashlight blow received during a DUI traffic stop.Footnote 6
  4. A Minnesota man was awarded $35,000 in punitive damages against an officer who struck him with a flashlight at a tavern disturbance; his injuries were minimal (only $2,000 in compensatory damages were awarded). Footnote 7
  5. A Michigan man received $200,000 for his injuries and another $250,000 in punitive damages against a police officer who broke up a bar fight. The plaintiff proved the officer struck him in the face with a flashlight, breaking his noses. Footnote 8
  6. Because officers are trained not to strike a person in the head with a weighted flashlight, there is the risk of criminal prosecution of officers who, under stress, react with a blow to the head of the resisting person. In such cases, the indictment may be for a felony (assault with a deadly weapon).Footnote 9

Blackjacks, Saps, and Billies

In years past, many officers carried, in their back pockets, a blackjack made of stiff leather, a sap or similar weapons. A billy is a short stick, like a truncheon.Footnote 10 The use of these weapons has generated controversy in recent years.


  1. They are readily concealable weapons, of low cost.
  2. They are easily carried, and are lightweight.


  1. They are too short to be an effective weapon.
  2. They have sharp edges.
  3. Many saps have loops, which constrict an officer's hands.
  4. Because of the flexible nature of the design, they fail to generate enough shock waves to be effective.
  5. They tend to be used with facial/head blows, with the same kind of trauma associated with flashlight injuries (see above).


  1. A federal court in Washington refused to dismiss a suit against the chief of the D.C. Police Dept. by an injured man for allowing officers to carry blackjacks without adequate training. Footnote 11
  2. A Connecticut man was awarded $227,500 for head injuries caused by an officer-inflicted blow with a pocket-sized stick; $100,000 was in punitive damages against the city for the negligent failure to provide adequate training. Footnote 12

The Baton

The typical baton is a round stick of various lengths, and is made of hardwood, aluminum or plastic composite materials.


    1. It is a lightweight weapon, and inexpensive.
    2. The public is accustomed to seeing police officers and security guards routinely carry them.
    3. It has greater reach than blackjacks, short billies or flashlights; it has greater utility and flexibility as an impact weapon.
    4. A blow with a baton can immobilize a combative person; it can disarm him if he is carrying an offensive weapon.
    5. Competent training is available from a multitude of public and private trainers.
    6. The baton can be used as a "come-along" device in some situations.
    7. A baton can be used in a non-offensive blocking fashion, to ward off blows or to push back an attacker.
    8. Manufacturers recommend their products as impact weapons.


  1. They are cumbersome, and therefore, are often left in the car.
  2. They are not concealable, and are not well suited for plainclothes officers.
  3. They are often in the way when an officer is running.
  4. They can be lost if they fall from a belt ring, and create a hazard.
  5. It is difficult or impossible to avoid head strikes in all cases, particularly in combat situations. Although intensive training minimizes this risk, it cannot entirely eliminate it. Paralysis or death may result, even days later, caused by subdural or bilateral hematoma.
  6. Facial strikes often cause lacerations and substantial blood loss. This impairs the department's public image, when citizens observe blood-splattered injuries on TV news programs, or at the scene of arrest, or while visiting a hospital emergency room.
  7. Departments must periodically retrain officers to maintain baton proficiency.


  1. An Illinois man accepted a $127,000 settlement for a skull fracture caused by a baton strike received during a tavern brawl , with police officers. Footnote 13
  2. A Michigan man received $35,000 inpunitive damages, $5,000 for mental anguish and $5,000 for pain and suffering. Officers struck him in the groin and on his back when he assumed a "fighting stance." Footnote 14
  3. Four California residents received $43,000 from officers who broke up a loud party using batons, causing a fractured vertebra and a broken wrist. Footnote 15

The 'Come-along' Hold

Although some agencies train officers in (and some manufacturers advocate) the use of the baton as a "come-along" device, substantial field experience indicates that officers rarely use their batons for that purpose. While trainers are able to demonstrate the use of batons for pain-compliance purposes in a sterile classroom setting, there are marked differences between a static demonstration and the dynamics of a hostile field confrontation. Specifically, officers frequently state they are unable to get a disobedient or resisting person to stand still long enough to properly apply a baton come-along hold.

A cautionary note is in order concerning the training of officers in the use of a baton for come-along holds. In at least one case, a police officer (who was a certified baton trainer) testified in a personal injury suit that it was negligent for an officer to use a side-handle baton as an impact weapon, without first attempting to apply come-along holds with the baton. Another expert witness, who specializes in use-of-force training, testified that it was proper for the defendent officer to initially resort to the use of his baton as an impact weapon, without first attempting compliance with baton-assisted come-along holds. Fortunately, the jury agreed with the second witness, and found no liability against the officer or his employing municipality Footnote 16

Should officers be trained in the use of a baton for come-along holds? If the department provides such training, but officers routinely avoid using the technique, this behavior will be criticized by the plaintiff's lawyer. Opposing counsel will suggest that since officers were and are presently trained in the use of batons for come-along holds, it was negligence not to utilize these holds before employing the baton as an impact weapon.

Thus, a good argument can be made for NOT TRAINING officers in the use of baton-assisted come-along holds, if batons are not routinely used for such purposes in field confrontations. As was previously mentioned, many officers avoid using their batons for comealong holds, because the dynamics of a hostile confrontation make it difficult, if not impossible, to successfully apply these holds to a resisting person. Moreover, many trainers believe that hand-applied pain compliance techniques are tactically superior to baton-applied come-along techniques.

The Baton Design Controversy

In 1974 the traditional straight baton was optionally modified by adding a side handle. The leading manufacturer of side-handle batons publishes training material, and also trains and certifies instructors.Footnote 17 However, many professional trainers continue to prefer the traditional "straight baton.."Footnote 18 Aside from the potential use of a baton for come-along holds, both batons are effective weapons.

Those trainers who prefer the side-handle baton believe it:

  1. generates more power,
  2. is easier to control,
  3. is more versatile, and
  4. is less likely to be seized by an opponent.

Those trainers and officers who prefer the straight baton believe that it:

  1. generates greater fluid shock waves (which inflict more trauma but cause less damage to tissue)
  2. is superior when used in confined locations,
  3. is easier, quicker and more economical to train officers to a satisfactory level of competency,
  4. is no more likely to result in unintended head strikes than the side-handle baton,
  5. has a shorter recovery time (for additional strikes), and
  6. is more effective when used by shorter and smaller officers, particularly the new small-diameter lightweight models.

An expandable model of the straight baton is available, and is particularly suitable for plainclothes and special duty officers. An all-metal tokushu keibo collapsible/extendable baton has been in use by some Japanese police officers since 1966, and is currently issued to members of the Secret Service and U.S. Capitol Police. Japanese experience indicates the weapon is more effective than the wooden baton and causes less bodily harm.


Many neck holds used by officers trace their origin to sport judo. The most traditional restraint is the arm bar which applies pressure with the forearm across the front of the neck. Because this technique cuts off the victim's air supply, it has been widely rejected by police trainers. As with a drowning swimmer, the procedure sometimes precipitates resistance as the person fights for air.

The carotid restraint is taught by many law enforcement agencies. It involves application of the forearm to one side of the neck, and the bicep area of the arm to the opposite side of the neck. The crux of the elbow is positioned at the front of the throat, with particular care so as not to apply pressure to the esophagus.

The (Kansas City) lateral vascular neck restraint is distinctive, in that three levels of control are present. Unlike the carotid restraint which produces unconciousness, this method emphasizes capturing an arrestee's balance, and the application of pressure in an escalating series of steps. The procedure is also characterized by a more dynamic "pull through" application method, than the fixed compression technique of the carotid restraint.


  1. Neck restraints are effective, regardless of the size of the officer relative to the person to be controlled.
  2. Unlike batons, the procedure does not require a lot of room for striking distance; it is possible to employ grappling procedures and neck restraint in close contact, in narrow or cluttered premises.
  3. Neck restraints are an attempt to provide "humane" means of controlling combative persons without the necessity of striking them, thus minimizing the risk of broken bones, lacerations and other impact-related trauma.


  1. Neck restraints, if applied improperly, have caused death or paralysis.
  2. Due to the dynamics of a violent struggle, it is often difficult to correctly apply such methods.
  3. Several instances of "unexplained" death have followed purportedly proper application of the technique, unaccompanied by any discoverable physical injuries. This phenomena, known as "custody death syndrome," is not fully understood, and research is still ongoing.
  4. Perpetual and time-consuming training is needed to maintain minimum levels of proficiency.
  5. During litigation, it is difficult to precisely explain to a jury the physiological effects of neck restraint procedures, due to an inadequate base of undisputed medical evidence. Even within the medical community, there are disagreements regarding the mechanism that causes unconciousness.
  6. It is difficult for an officer to monitor and control the amount of pressure applied during the procedure.
  7. Once the restraint has been applied, there is a need to closely monitor the arrestee. This may be impractical when the individual is hooked into a detention facility operated by another agency.


  1. A Chicago family accepted a $500,000 settlement for the death of a man who died from a bar-arm hold. The city offered the settlement despite the fact it did not authorize the hold and instead teaches the carotid restraint method. Footnote 19
  2. Claiming a bruise and humiliation, an off-duty California sheriffs deputy received $13,360 after being choked by city police officers who did not know he was a peace officer and believed him to be armed. Footnote 20
  3. A male homosexual received $250,000 for abnormal brain waves, following a choke-hold applied by officers who precipitated a confrontation. The officers observed him kissing a male friend and asked for his ID, which started a verbal confrontation, leading to his forcible arrest. Footnote 21
  4. Responding to a domestic disturbance, D.C. police officers used a baton to apply pressure to the back of a man's neck, while he laid face-down on the floor -- causing death by asphyxiation. Although PCP, marijuana and hashish were found in his system, the jury awarded $950,000 to his estate, widow and daughter.Footnote 22


Several sprays and gases have been on the market for many years, and are marketed under various trade names. In some states, aerosol tear gas is purchasable by any citizen, and may be lawfully carried. Some states restrict sales and possession to citizens who have taken a four or eight hour training course


  1. Tear gas cannisters are inexpensive.
  2. They are lightweight, and easily carried and concealed. They can be used by uniform and plainclothes officers.
  3. Sprays do not require extensive training.
  4. No physical contact is needed.


  1. Chemical agents are not effective on many individuals, especially the mentally disturbed, those who are intoxicated, and persons under the influence of certain drugs.
  2. Some individuals may become more combative when they experience the discomfort associated with chemical irritants.
  3. There is a time lag between application and effect; they may not stop aggressive behavior rapidly enough.
  4. A person with a knife or blunt instrument who has impaired vision from the spray may lash out in an indiscriminate manner.
  5. Some individuals who suffer from pre-existing respiratory problems may experience serious medical problems.
  6. The sprays can seriously irritate and harm one's eyes, unless the eyes are thoroughly washed.
  7. Wind direction can cause the officer to be inadvertently affected by the spray, and make him vulnerable to a potentially fatal attack.
  8. Officers may object to transporting prisoners who have clothing saturated with a chemical irritant.


  1. A farmer who was part of an organized farm protest in Washington drove his tractor on a sidewalk. D.C. Police officers threw a tear gas capsule inside, which caused permanent vision loss in one eye. The jury awarded him $400,000. Footnote 23
  2. A federal court in Virginia upheld the use of tear gas on a prison inmate who was vandalizing his cell. The procedure minimized potential resistance to corrections officers who subdued him.Footnote 24


Recent technology has allowed the development of small batteries and improved discharge units. Typically, such devices discharge a high voltage spark (50,000 volts) at very low amperage (0.3 joules). One such hand-held device is pressed against the combatant, who is quickly downed. Another device (the Taser®) fires small darts, connected to wires, accomplishing the same objective at a safer, non-contact distance.


  1. These devices are easily carried. They are lightweight and affordable.
  2. Extensive training is not required.
  3. They may be more effective on persons under the influence of PCP and other drugs who do not respond to chemical irritants.
  4. They are especially useful for controlling non-criminal violent behavior, such as persons who are mentally impaired, or under the influence of mind-altering substances.
  5. It may be unnecessary to resort to firearms to control a person armed with a knife or blunt instrument. The Taser® is effective at distances of up to 12-15 feet.
  6. The Los Angeles Police Dept. has extensive experience in using the Taser®, beginning in May of 1980. As of early 1987, the L.A.P.D. possessed 550 Taser®s and had employed the device 775 times.Footnote 25


  1. There are allegations the electrical spark can cause scars or burn marks.
  2. Long-term medical studies are non-existent. In a California study of 218 persons stunned with the Taser®, three persons died--although these individuals may have perished from the effects of PCP. Footnote 26
  3. The spark can cause a fire hazard if flammables are present. In Ontario, California, a man soaked with gasoline was incinerated when officers shot him with a Taser®.
  4. Hand-held devices have been misused to produce discomfort, when administered by sadistic officers.
  5. Media and constituent representatives have labelled the devices as "cattle prods," associated with civil rights demonstrations in the Sixties.
  6. The manufacturers of electrical weapons may be unwilling to provide testimony or litigation support services.
  7. They may not carry product liability insurance at the time the suit is filed, or the policy may not be effective for the period when the device was manufactured or sold.


  1. A federal civil rights suit filed in Atlanta complains a Stun Gun "burned permanent, ugly, disfiguring scars into the flesh of the plaintiff's body." The suit alleged the "brutal attack" caused pain, suffering, mental anguish and public humiliation.Footnote 27 The cost of defending such suits must be considered before electrical weapons are issued or authorized.
  2. A Federal Court in Nevada ruled for prison officials in a suit brought by an inmate who objected to the use of the Taser® to control obstreperous prisoners. The court upheld a prison regulation that allows the use of the Taser® or stun guns when inmates refuse to vacate their cells. The court said the weapons are more suitable than batons, and would inflict less discomfort on others than tear gas. Footnote 28


    1. Collect and preserve all brochures and other literature published by the manufacturer and distributor for each type or model of weapon purchased.
    2. Create a written memorandum-style record of any conversations with sales personnel concerning the merits of their product, its suitability for specified purposes, and any statements made which are intended to alleviate your questions concerning civil liability; attach a copy of the memo to the purchase order for the product.
    3. Insist on receiving a photocopy of the products liability insurance policy issued to the manufacturer and/or distributor.
    4. Require vendors to provide a list of all former and pending claims and litigation against the product under consideration, including names of legal counsel and the result or status of each claim.
    5. Ask your legal counsel to consider a third-party claim against the manufacturer and/or distributor of any product which is the subject of a claim or lawsuit against your agency or personnel.
    6. Don't wait for a lawsuit before preparing your defense. The time to line up expert witnesses in support of a particular weapon or tactic is now. If possible, get written recommendations from any consultants used, and a committment from each consultant that he will appear in court to defend his recommendations, if necessary.
    7. Law enforcement administrators should unhesitatingly initiate disciplinary action against subordinate officers who carry or use unauthorized weapons (or who use unauthorized control techniques), even if otherwise appropriate or excusable under the particular circumstances. Disciplinary action should fit the offense and eggregiousness of the conduct; in some cases, a written reprimand will be sufficient, in others, more severe action is warranted. The failure to administer cautionary discipline can itself predicate the liability of a law enforcement agency. It will be easier for plaintiffs counsel to prove that superior officers knew (or should have known) such weapons or techniques were likely to be used in the instant case.


    The use of force and weapons by law enforcement officers is one of the most visible and controversial aspects of policing. It is likely to remain so.

    A law enforcement agency must carefully choose the various devices and techniques it will authorize for the protection of its officers and the public. In making policy decisions in this area, an agency should consider existing court decisions and litigation trends.

    No matter what policies an agency adopts, the use of force by officers should be carefully monitored on a continuing basis. An agency should not hesitate to alter its policies when circumstances so indicate.

    In our efforts to continually assist the law enforcement community, AELE welcomes comments, information and suggestions. We are especially interested in lawsuits, verdicts and testimony by expert witnesses.


    This document was co-authored by an experienced police defensive-tactics instructor and an attorney who specializes in law enforcement liability research. It was formally reviewed by two outside legal counsel; one is an instructor at a nationally prominent university-based police training center, and the other serves as chief legal counsel to a large police agency. It was also reviewed by a trial lawyer who has more than 20 years experience in defending police use-of-force lawsuits.

    This paper does not attempt to raise all of the strengths or weaknesses of any non-lethal weapon or control tactic. The litigation examples merely illustrate the kinds of civil actions that have been brought against law enforcement agencies and personnel; they are not intended to discourage the proper use of any accepted defense or control tactic, method or commercially marketed product. AELE has provided this summary as a starting point for the ongoing discussion and debate over the weapons, techniques and tactics described herein.


    1. The Confrontational Continuum model developed by Kevin Parsons and Associates was copyrighted in 1980. Dr. Parsons is a nationally prominent police training provider, and has testified as an expert witness in more than fifty lawsuits alleging excessive force by law enforcement personnel.
    2. IACP 1987 Annual Law Enforcement Survey: Executive Summary, 55 (I) The Police Chief 38 [at 39] (January, 1988); Gaithersburg, MD.
    3. Statement of George Hoffman, President of L.A. Screw Products Police Equipment Division in a letter to the editor of Police Product News, replying to an article in the November, 1980 issue entitled Dueling Flashlights.
    4. Wyche v. City of Los Angeles, 103 L.E. Liab. Rptr. (AELE) 4, Super. Ct., Los Angeles, Co. Cal. (1980); the city dropped an appeal and paid the plaintiff.
    5. Steinnagle v. Frazer, 124 L.E. Liab. Rptr. (AELE) 3, Cm. Pls. Ct., Bucks Co., Pa. (1/8/83).
    6. Wellington v. Daniels, 125 L.E. Liab. Rptr. (AELE) 3, modif. 127 L.E. Liab. Rptr. (AELE)4, Civ. No. 81-208-NN (E. D. Va. 1982); the city was dismissed from the suit on a motion for judgment N.O.V. because the municipality did not provide the flashlight and there was no evidence the city allowed the officer to carry it. A single instance of excessive force does not create a "policy or practice" under Monell v. Dept. of Social Services, 436 U.S. 658 (1978). See City of Oklahoma City v. Tuttle, 105 S. Ct. 2427 (1985).
    7. Melina v. Chaplin, 112 L.E. Liab. Rptr. (AELE) 5, Dist. Ct., Hennepin Co. Minn. (1981).
    8. Arnold v. Pydyn, 159 L.E. Liab. Rptr. (AELE) 5, U.S. Dist. Ct. (E.D. Mich. 11/24/85).
    9. People v. R.C S., Los Angeles County Superior Court No. A-781184 ( 1987),
    10. For a legal definition of a billy or blackjack, see Annotation, "What constitutes a 'bludgeon, 'blackjack,' or 'billy' within meaning of criminal possession statute," 11 ALR 4th 1272 (1982).
    11. Hardeman v. Clark, 593 F. Supp. 1285 (D.D.C. 1984). 1
    12. Ieva v. Stamford, 110 L.E. Liab. Rptr. (AELE) 11, U.S. Dist Ct. (D. Conn. 1981).
    13. Van Ham v. City of Aurora, 131 L.E. Liab. Rptr. (AELE) 3, U.S. Dist. Ct. (N.D. I11. 1983}.
    14. Shulick v. Floyd, 113 L.E. Liab. Rptr. (AELE) 4, U.S. Dist. Ct. (W.D. Mich. 1981).
    15. Lopez v. Grant, 111 L.E. Liab. Rptr. (AELE) 4, Super. Ct. Santa Clara Co. Cal. (1981).
    16. Fronk v. Meager, No. Dak. Supreme Ct. No. 870085, -- N.W. 2d -(N.D. Dec 29, 1987).
    17. See The Monadnook PR-24 "Prosecutor", a training manual by Richard R. Starrett, Monadhock Lifetime Products. Fitzwilliam NH. Lib. Cong. Cat. No. 76-6768 (1976).
    18. See The Koga Method: Police Baton Techniques, by Robert K. Koga and John G. Nelson, Glencoe Press/Macmillan Co., Beverly Hills CA, Lib. Cong. Cat. No. 68-19201 (1968).
    19. Nethery v. City of Chicago, 136 L.E. Liab. Rptr. (AELE) 3, Cir. Ct., Cook Co. Ilk No. 81-C 2911 (1983).
    20. Stevens v. City of Los Angeles, I11 L.E. Liab. Rptr. (AELE) 12, Super. Ct., Los Angeles Co. Cal. (1981).
    21. Barlow v. City of Long Beach, 145 L.E. Liab. Rptr. (AELE) 3, Super Ct., Los Angeles Co. Cal. (1984).
    22. Utley v. Dist. of Columbia, D.C. Super. Ct. No. 1558-83, 29 ATLA Law Rep. 32 (1986).
    23. District of Columbia v. Colston, 468 A. 2d 954 (D.C. App. 1983).
    24. Greear v. Loving, 391 F. Supp. 1269 (W.D. Va. 1975).
    25. "Los Angeles P.D. finds Taser® stunningly effective," Torrance Daily Breeze, reprinted in PORAC News (Feb. 1987), p. 13
    26. "Study Finds Safer Than Guns: King Hospital Doctors Compare Outcomes of Victims," Los Angeles Times, Jan. 16, 1986), Part V, p. 22.
    27. [Nancy Moore] Smith v. [Officer P.L.] Wood et al, U.S. Dist. Ct. No. C86-1152A (N.D. Ga., filed 6/19/86).
    28. Michenfelder v. Sumner, 624 F. Supp. 457 fat 463-4] (D. Nev. 1985).

    FIGURE 1:

    Research funding for this document was generously provided by MARKEL SERVICE, INC. Law Enforcement and Public Officials Liability Insurance Underwriters and Brokers

    Copyright by Americans for Effective Law Enforcement, Inc. Permission to reproduce or republish, but not for profit is granted provided appropriate credit is given AELE.