The following excerpt is from Southerland v. City of New York, Docket No. 07-4449-cv (L), Docket No. 07-4450-cv (CON) (2nd Cir. 2012):
Second, a child might assert that the seizure was carried out in an unreasonable manner, such as through the use of excessive force or through a sudden, surprise raid. See, e.g., Brokaw v. Mercer County, 235 F.3d 1000, 1011-12 (7th Cir. 2000) (upholding manner-of-seizure claim brought by child removed from his home where officers "acted like kidnappers").
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