Fourth Circuit: Estate of Ronald Armstrong v. The Village of Pinehurst

S1983 / use of force

Qualified immunity for taser use against nonviolent resistence by arrestee (securing himself to a stop sign).

Opinion is precedential as to use of force in future, though, holding that stationary and nonviolent resistance by mentally ill arrestee not deemed a threat to others is excessive.

Concur in part: Not a 4A violation - overdeterrence.

http://www.ca4.uscourts.gov/Opinions/Published/151191.P.pdf