What is the test for determining whether a defendant has a constitutional right to exercise reasonable force in the custody of a federal prison?

Courts "must also account for the legitimate interests that stem from [the government's] need to manage the facility in which the individual is detained, appropriately deferring to policies and practices that in th[e] judgment of jail officials are needed to preserve internal order and discipline and to maintain institutional security." Id. (quoting Bell v. Wolfish , 441 U.S. 520, 540, 547, 99 S.Ct. 1861, 60 L.Ed.2d 447 (1979) (internal quotation marks omitted)). The following considerations may bear on the reasonableness or unreasonableness of the force used: "the relationship between the need for the use of force and the amount of force used; the extent of the plaintiff's injury; any effort made by the officer to temper or to limit the amount of force; the severity of the security problem at issue; the threat reasonably perceived by the officer; and whether the plaintiff was actively resisting." Id. This list is not exclusive. Id.

2. Whether Plaintiff Has Alleged a Violation of a Constitutional Right

Plaintiff alleges that while he was a pretrial detainee in the custody of the San

[485 F.Supp.3d 1255]