The following excerpt is from Lowry v. City of San Diego, 818 F.3d 840 (9th Cir. 2016):
5 Similarly, the City argues that, under our decision in Frunz v. City of Tacoma, officers responding to a "burglary in process" are entitled to "assume that the suspects will, if confronted, flee or offer armed resistance." 468 F.3d 1141, 1145 (9th Cir.2006) However, Frunz did not address whether the officers' use of force was reasonable. Id. at 1144. Instead, that case considered only whether the officers' warrantless entry into a home was justified. Id. at 1144. Accordingly, Frunz has little relevance to our current inquiry.
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