The following excerpt is from Alvarado v. Tackett, Case No.: 13-CV-1202 W (JMA) (S.D. Cal. 2018):
"The police on an occasion calling for fast action have obligations that tend to tug against each other . . . . [t]heir decisions have to be made 'in haste, under pressure and frequently without the luxury of a second chance.' " Lewis, 523 U.S. at 853 (quoting Whitley v. Albers, 475 U.S. 312, 320 (1986)). "[I]n such circumstances only a purpose to cause harm unrelated to the legitimate object of arrest will satisfy the element of arbitrary conduct shocking to the conscience, necessary for a due process violation."6 See id. at 836.
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