Heredia v. Roscoe
Whether takedown maneuver to subdue arrestee was reasonable was for jury in light of evidence that officer grabbed arrestee from behind without identifying himself, that, although arrestee initially resisted officer, arrestee submitted to officer and raised his hands once he realized it was officer, rather than one of his friends, that had grabbed him, that arrestee was not trying to attack anyone at that time, and that takedown caused arrestee to hit his head on pavement; right to be free from an increased use of force after arrestee has submitted to arrest and put up his hands was clearly