The following excerpt is from Nelson v. Butte Cnty. Sheriff's Dep't, No. CIV S-09-2776 EFB P (E.D. Cal. 2012):
violated the Eighth Amendment: (1) the need for the use of force; (2) the relationship between the need for force and the amount used; (3) the extent of injury inflicted; (4) the extent of the threat the officers reasonably perceived the plaintiff to pose to staff and inmate safety; and (5) any efforts made to temper the severity of the forceful response. Whitley v. Albers, 475 U.S. 312, 321 (1986).
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