The following excerpt is from C.B. v. City of Sonora, D.C. No. 1:09-cv-00285-AWI-SMS, No. 11-17454 (9th Cir. 2013):
The district court also ignored precedent from other circuits indicating that handcuffing during the course of an otherwise lawful arrest ordinarily fails to state an excessive force claim. See Brown v. Gilmore, 278 F.3d 362 (4th Cir.
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