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Task: Use of Canine as Force






          Kuha v. City of Minnetonka,   328 F.3d 427 (8th Cir. 2003).

               A jury could properly find it objectively unreasonable to use a police


               dog trained in the bite and hold method without first giving the
               suspect a warning and opportunity for peaceful surrender.






          Robinette v. Barnes, 854 F.2d 909 (6 Cir. 1988).
                                                                           th
               The use of a properly trained police dog to apprehend a felony

               suspect does not constitute a use of deadly force.  In this case the

               canine seized the suspect’s neck because it was the only part of his

               body exposed.  As a result, the suspect died.














                                     ©2021 Jack Ryan  Legal & Liability Risk Management Institute                                    66
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