The following excerpt is from Shepard v. Bass, CASE NO. 1:10-cv-00754-LJO-BAM PC (E.D. Cal. 2012):
was blocked by bodies of inmates did not violate Eighth Amendment); Jennings v. Hays, No. 3:10-cv-08004 PCT-JAT (JRI), 2011 WL 1480038, *7 (D.Ariz. Apr. 9, 2011) (application of pepper spray to prisoner who was refusing to comply with orders does not amount to excessive force).
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