Rosales v. Bradshaw
Deputy's use of force when seizing motorist for minor traffic violations was excessive even though motorist was openly carrying firearm; threat posed by armed suspect is assessed using set of nonexclusive factors, including: (1) whether officers ordered suspect to drop his weapon, and suspect's compliance with commands; (2) whether hostile motions were made with weapon towards officers; (3) distance separating officers and suspect; and (4) suspect's manifest intentions.