The following excerpt is from Grant v. Lockett, 19-1558, 19-469, 19-738 (2nd Cir. 2021):
The district court's instruction neither misled the jury nor inadequately informed the jury of the law. Although the instruction did not overtly specify that police may handcuff an individual in the absence of probable cause, it plainly indicated that officers may use handcuffs for safety reasons alone and was thus responsive to the jury's question. Mirroring language from our caselaw, the instruction correctly informed the jury that a police officer may use handcuffs during a stop "when the police have a reasonable basis to think that the person detained poses a present physical threat and that handcuffing is the least intrusive means to protect against that threat." United States v. Fiseku, 915 F.3d 863, 871 (2d Cir. 2018) (internal quotation marks and emphasis omitted). Therefore, the district court's supplemental jury instruction was not erroneous.
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