The following excerpt is from Dodd v. City of Norwich, 827 F.2d 1 (2nd Cir. 1987):
(1) Once a police officer applies a single handcuff to an arrestee, the "seizure" is complete for fourth amendment purposes (indeed, "for all intents and purposes"), and there is no duty of reasonableness under Tennessee v. Garner, 471 U.S. 1, 105 S.Ct. 1694, 85 L.Ed.2d 1 (1985), for anything that follows.
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