When investigating a burglary, when confronted with signs of a break-in, can a police officer use excessive force against a suspect?

Our precedents make it clear that, when confronted with signs of a burglary, investigating officers are entitled to protect their own safety. "[B]urglary and attempted burglary are considered to carry an inherent risk of violence." Sandoval v. Las Vegas Metro. Police Dep't, 756 F.3d 1154, 1163 (9th Cir.2014). "Normally, when officers suspect a burglary in progress, they have no idea who might be inside and may reasonably assume that the suspects will, if confronted, flee or offer armed resistance." Frunz v. City of Tacoma, 468 F.3d 1141, 1145 (9th Cir.2006). "So long as the officers have established probable cause for a burglary, [i]n such exigent circumstances, the police are entitled to enter immediately, using all appropriate force. " Sandoval, 756 F.3d at 1163 (quoting Frunz, 468 F.3d at 1145 ). While it is true, as the majority observes, that the legal issue in Frunz concerned a Fourth Amendment claim of warrantless entry rather than a claim of excessive force, that distinction does not contradict the factual truth of our observation in Frunz. Neither does it affect the analysis as to the City's interest in the use of force, where the concern is not with the nature of the force used but rather whether the suspect posed a threat to the officers. The factual reality of this threat is not dependent on the point of law at issue.