Recent Developments
in the Court of Appeals
and the U.S. Supreme Court
USE OF FORCE - DOG BITE
Crenshaw v. Lister, 556 F.3d 1283 (11th Cir. 2009)
(where officer believed plaintiff was armed and dangerous in woods at night, officer entitled to summary judgment although he did not call off dog until after plaintiff was handcuffed even though he was not resisting, and plaintiff was bit 31 times; not unreasonable to give no warning where officer would have to reveal his position to potentially armed fugitive in wooded area at night).
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