Denial of qualified immunity for trigger-happy tasing of diabetic driver. Driver's attempt to remove one of the taser wires might have been resistance (pun?) but as the subsequent (fourth) tasing was underway already, it wasn't excused.
http://media.ca11.uscourts.gov/opinions/pub/files/201616804.pdf
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.