Duffield v. United States

How later courts describe this case

• determining when physical tort amounts to a section 1983 action involves inquiry into the amount of force used compared to the need presented, the extent of injury inflicted and the motives of the state officer
• Fourteenth Amendment excessive force claim by mother of pretrial detainee killed by jail guards after detainee became violent and guards attempted to subdue him
• prison guards' fatal choke hold on a prisoner in order to protect their own safety and maintain order was not sufficiently egregious so as to rise to the level of a violation of the prisoner's eighth amendment rights