The following excerpt is from Toscano v. City of Fresno, Case No. 1:13-cv-01987-SAB (E.D. Cal. 2015):
Where actual deliberation is practical, then deliberate indifference by the officer may suffice to shock the conscience. Wilkinson v. Torres, 610 F.3d 546, 554 (9th Cir. 2010). This standard will apply when the time frame involved makes it practical for the officer to actually
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