You have a suspect in custody. How much force is reasonable to use in restraining them after they’ve been subdued? This appeal from an Arizona in-custody death could have serious implications for how you subdue and continue to restrain a subject out in th

Legal Concepts and Case Citation 
Use of force 
The doctrine of qualified immunity 
The use of a RIPP restraint in subduing a resisting suspect 
Subduing a resisting suspect by a knee to the suspect’s back 
Gonzalez v. City of Phoenix (9th Cir. Jan 8, 2026) 163 F.4th 1289 

Rule: Once a violent drug-induced subject is subdued, officers must lessen the force being used to the point where the danger to the subject is minimized to the extent possible without losing control of him.Tightening a RIPP restraint beyond what is allowed, particularly when added to an officer kneeling on the subject’s back, has the potential of seriously injuring or killing the subject and generating potential civil liability for the officers involved.  

Summary: After pursuing and apprehending Ramon Timothy Lopez, who had taken methamphetamine, and after a foot chase on a hot August day in Phoenix, Arizona, officers of the Phoenix Police Department caught him, pulled him to the ground, and handcuffed him. Because he was still resisting, officers rolled him onto his stomach and – as one officer pressed his knee into Lopez’s back – applied a RIPP restraint,connecting ankle restraints to his handcuffed wrists behind his back, causing Lopez’s body to bend ....