To provide Officers with guidelines on the reasonable use of force.
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- Debra Phebe Cameron
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1 MODESTO POLICE DEPARTMENT GENERAL ORDER Number 1.06 Date: I. SUBJECT: USE OF FORCE II. PURPOSE: To provide Officers with guidelines on the reasonable use of force. III. POLICY: It is the policy of this department that Officers shall use only that amount of force which reasonably appears necessary, given the facts and circumstances perceived by the Officer at the time of the event, to effectively bring an incident under control. (1.3.1) IV. DEFINITIONS: A. Force: The use of any weapon, instrument, device or physical power to control or restrain a person, or overcome resistance. B. Lethal Force: Any use of force that is likely to cause death or serious physical injury. C. Less Lethal Force: Any use of force that is not likely to cause death or serious physical injury. D. Reasonable Cause: Refers to the set of circumstances the Officer is confronted with at the time the decision to use lethal force is made and that any reasonable Officer would conclude that level of force was appropriate. E. Imminent Danger: The threat of death or serious physical injury is immediate and unequivocal. Page 1 of 19
2 F. Serious Physical Injury: A bodily injury that creates a substantial risk of death; causes serious, permanent disfigurement; or results in long-term loss or impairment of the functioning of any bodily member or organ. V. PROCEDURE A. California Penal Code Section 835 (a) provides that: Any peace Officer who has reasonable cause to believe that the person to be arrested has committed a public offense may use reasonable force to effect the arrest, prevent escape or to overcome resistance. A peace Officer who makes or attempts to make an arrest need not retreat or desist from his/her efforts by reason of resistance or threatened resistance of the person being arrested; nor shall such Officer be deemed an aggressor or lose his/her right to self-defense by the use of reasonable force to effect the arrest or to prevent escape or to overcome resistance. B. Reasonableness" of the force used must be judged from the perspective of a reasonable Officer on the scene at the time of the incident. C. No procedure can realistically predict every possible situation an Officer may encounter in the field, therefore, it is recognized that each Officer must be entrusted with well-reasoned discretion on determining the appropriate use of force in each incident. Officers are not required to use the least intrusive degree of force possible but are required to use reasonable force. D. While it is the ultimate objective of every law enforcement encounter to minimize injury to everyone involved, nothing in this General Order requires an Officer to actually sustain physical injury before applying reasonable force. E. Application of Force 1. It is recognized that Officers are expected to make split-second decisions and that the amount of time available to evaluate and respond to changing circumstances may impact an Officer s decision. It is also recognized that Officers have to make these decisions in situations that are tense, uncertain, and rapidly evolving and must use the appropriate level of force to handle such situations. 2. When determining whether or not to apply any level of force and evaluating whether an Officer has used reasonable force, a number of factors should be taken into consideration. Those factors should include, but are not limited to: Page 2 of 19
3 a. The conduct of the individual being confronted (as reasonably perceived by the Officer at the time). b. Officer/subject factors (age, size, relative strength, skill level, injury, exhaustion, number of Officers and/or subjects). c. Influence of alcohol/drugs, and the mental or physical capacity of the subject(s). d. Proximity of weapons. e. Availability of other options (what resources are reasonably available to the Officer under the circumstances). f. Seriousness of the suspected offense or reason for contact with the subject. g. Training and experience of the Officer. h. Potential for injury to citizens, Officers and suspects. i. Risk of escape. j. Other exigent circumstances. VI. FORCE OPTIONS It would be unreasonable to assume that each force option must be used in every situation. The force options are intended as a general guideline for Officers to follow, and actions by the suspect may justify bypassing an option or options in either direction in order to effect compliance by the suspect. A. No Force: No physical contact is made. Examples include physical/command presence and voluntary compliance out of respect for the law and authority. B. Verbal communication skills: Gaining control through specific directions in a polite, respectful, and professional manner Step 2. 5 Step 3. S A F E R C. Controlling Force: Less Lethal physical arrest/control techniques designed to control a subject and minimize the possibility of injury. Examples include: (1.3.4) 1. Wrist/arm locks and other control holds: Techniques used to control or escort passively resistive suspects. These leverage holds isolate the joints or tendons of the body, and control is achieved through body mechanics or pain stimulus. Once compliance is obtained, the force shall be reduced. Page 3 of 19
4 2. Take downs (hair pull, leg sweep, reap throw): Used to diffuse a potentially violent suspect, or as a movement towards a control hold involving a non-cooperative person. They are applied through pain stimulus and body leverage, and are designed to establish control by placing a subject on the ground. 3. Carotid Control Hold (lateral vascular restraint): A restraint hold in which the Officer s arm is used to decrease the flow of oxygenated blood through the two carotid arteries leading to the brain. The goal of the Carotid Control Hold is to stop a subject s resistance by potentially rendering him/her unconscious. It is designed to take a subject to the ground and place the subject in a position to allow for ease of handcuffing. The Carotid Control Hold should only be used when lesser means of force are either not available or inappropriate for the circumstances. Other neck restraints such as the trachea hold and the bar arm hold are not authorized for use. NOTE: If a subject has been rendered unconscious, the subject shall be continuously kept under observation and transported to a medical facility for clearance. 4. The WRAP: A restraint system designed to immobilize a subject s lower extremity. It should be used after a violent / combative subject has been handcuffed and placed face down on the ground. It should only be used on the subject s lower extremities. Once applied, the subject shall never be left unattended. The WRAP should be used in the following situations: a. To immobilize a violent/combative subject and limit them from causing injury to themselves or others b. To prevent a violent/combative subject from causing property damage by kicking c. Transportation of violent / combative subjects d. Whenever violent/combative behavior is anticipated Page 4 of 19
5 D. Less Lethal Force Options 1. Any instrument, device, or physical power to control / restrain a person or overcome resistance that is not likely to cause death or serious physical injury, when used properly. 2. Only qualified personnel who have received approved training from a certified department instructor shall use department-approved Less Lethal Weapons as enumerated in this General Order and General Order All Less Lethal Weapons carried on duty shall be maintained in a clean, serviceable condition. Modifications to department approved and issued Less Lethal Weapons are not allowed. 4. Authorized less lethal weapons for the Modesto Police Department are: (this list does not include those instruments that may be used in an emergency situation) (1.3.9a) a. Personal Body Weapons (Hands, Fists, Feet, Knees, Elbows) b straight baton, black in color. c. PR 24 side handle baton. d. Expandable batons of 14, 21, 24, 26, 29, or 31. e. 42 Bokken baton f. Combined Tactical Systems (CTS) 12 gauge super sok #2581 Bean Bag or a beanbag of like design. g. Duty flashlights. h. Chemical agent. i. The TASER conducted energy weapon. j. The Pepper Ball SA200 Chemical (PAVA) Projectile Launcher k. Police Canines (See Departmental K9 Manual and applicable General Order) 5. Chemical Agents Depending on an individual s reaction, Chemical Agents can sometimes resolve situations requiring force, without injury. When compared to impact weapons, injuries are less likely to occur using Chemical Agents. Page 5 of 19
6 a. Types of Chemical Agents: 1) Aerosol Chemical Agent - All liquid, gaseous, or solid substances intended to produce temporary physical discomfort through vaporization or dispersal in the air. (CN, CS, OC, PAVA). A common example of this type of Chemical Agent is Mace or Oleoresin Capsicum 2) Non-Aerosol Chemical Agent: Projectiles, grenades, wands, and shells, which are thrown or launched and dispersed by burning, blasting, or a mechanical device. (CN, CS, OC). 3) Pepper Ball SA200 Chemical (PAVA) Projectile Launcher: This force option is considered to be less lethal. Situations for the use of the Pepper Ball SA200 include but are not limited to: a. On self-destructive, dangerous, or highly combative subjects b. Instances when the use can be accomplished with a reasonable degree of safety to suspects, the public, and officers c. Circumstances where a tactical advantage can be obtained d. Crowd control/riot situations e. Training exercises or approved demonstrations Deployment of the Pepper Ball: 1) The Pepper Ball is not a substitute to Deadly Force. 2) If in a crowd control/riot environment, the Officer deploying the Pepper Ball should wear his/her MPD issued ballistic helmet. a. When deploying, every effort should be made to fire at the subject s center mass area, arms, and legs. b. Officers should generally avoid striking the head, neck, or spine. c. Prior to deployment, officers shall obtain supervisory approval when used on self- Page 6 of 19
7 destructive, dangerous, or highly combative subjects d. Prior to deployment, officers shall obtain supervisory approval when used in a crowd control situation e. In circumstances permitting where tactically feasible, the Officer deploying the Pepper Ball should call out Pepper Ball, loud enough for others to hear, prior to discharge. This is an effort to reduce the possibility of its discharge being mistaken for the sound of a gunshot. Pepper Ball Post-Deployment Responsibilities: After the Pepper Ball has been deployed, the officer shall: 1) If any person is struck with Pepper Ball(s), ensure the person(s) is medically cleared by medical personnel prior to booking or release from police custody. Advise medical and jail booking personnel of the Pepper Ball deployment, the number of times the subject was struck, and the observed effects, if any. If no person(s) is struck with Pepper Ball(s), refer to section (b) (4) below for medical clearance guidelines. 2) Fully document the circumstances of all Pepper Ball deployments in a Modesto Police report and Use of Force Memo. 3) Photograph the areas where the Pepper Balls contacted the subject and any additional injuries observed or sustained during the arrest process. b. Use Restrictions for Chemical Agents 1) An Officer must obtain Supervisory approval before using non-aerosol Chemical Agents. 2) Only Officers meeting state requirements and authorized by the Modesto Police Department may carry and use Non-Aerosol tear gas. 3) Officers may only use department approved Chemical Agent dispersal devices/weapons and the following Page 7 of 19
8 types of Chemical Agents: (CN Tear Gas; CS Tear Gas; OC Tear Gas (Pepper Spray), PAVA. 6. TASER X26 4) Treatment at a medical facility is no longer mandatory; however, if the subject has an unusual adverse reaction to the Chemical Agent, i.e. blistering of the skin or difficulty breathing, he/she shall be transported to a medical facility for treatment. a. The Taser X26 is and Electronic Control Device (ECD) that use propelled wires or direct contact to conduct energy to affect the sensory and motor functions of the nervous system. b. The use of the Taser X26 causes incapacitation and strong muscle contractions making secondary injuries a possibility. The potential injuries include but are not limited to: cuts, bruises, and abrasions caused by falling, and strain-related injuries from strong muscle contractions such as muscle or tendon tears, or stress fractures. These injuries are secondary in nature and not directly attributable to the electric output of the Taser X26 device but are possible consequences of the strong muscle contractions the Taser X26 device induces to produce incapacitation. c. Situations for use of the Taser X26 include, but are not limited to: 1) Subjects actively resisting and/or highly combative, exhibiting active aggression. 2) Instances when the use can be accomplished with a reasonable degree of safety to suspects, public, and Officers. 3) Circumstances where the tactical advantage can be obtained. 4) Supervisor approved training exercise or demonstration. Page 8 of 19
9 d. TASER X26 deployment considerations: 1) The Taser X26 shall not be carried on the same side as the Officer s duty weapon. Officers in plain-clothes assignments shall also carry the Taser X26 in an approved holster out of view. 2) The Taser X26 is not a substitute to Deadly Force. 3) When possible effort should be made to fire the Taser X26 at the suspect s preferred target area as depicted in blue on the diagram below. This preferred target area results in increased effectiveness by allowing the bottom probe to effect the lower extremities such as the pelvic triangle and legs. 4) No more than one Officer should deploy the Taser X26 against a suspect at a time. Page 9 of 19
10 5) In circumstances permitting where tactically feasible, the Officer deploying the Taser X26 should call out TASER TASER, loud enough for others to hear, prior to discharge. This is an effort to reduce the possibility of its discharge being mistaken for the sound of a gunshot. 6) Once the probes make contact, the Taser X26 will operate for a 5 second period. If the suspect is subdued prior to the 5-second period, shut off the Taser X26. 7) Whenever possible, the Officer in Charge (OIC) shall formulate a plan prior to Taser X26 deployment including, but not limited to: e. Drive Stun Mode a) An arrest team to take the suspect into custody. b) A cover team to provide protection for the Taser X26 operator and the arrest team. c) Alternative force options should be in place and/or considered should the use of the Taser X26 fail. 1) The Taser X26 functions in a stun mode after the probes have been fired, as a secondary / alternative, Less Lethal force option, especially in cases where the subject has continued active resistance and one or more of the probes have become free or the intended target was missed. 2) The Drive Stun Mode can be performed while a deployed air cartridge is still connected to the Taser X26. 3) To use the Drive Stun Mode without firing the probes, remove the live cartridge while the Taser X26 is turned off. 4) The Drive Stun Mode is strictly for pain compliance. It can be overcome by individual(s) under the influence of drugs and/or alcohol, Emotionally Page 10 of 19
11 Disturbed Persons (EDPs) or by focused, combative individuals. 5) For maximum effectiveness in Drive Stun Mode, aggressively drive the TASER X26 into these areas: a. Radial (forearm) b. Common peronial (Outside of thigh) c. Tibial (calf muscle) 6) The Drive Stun Mode to the neck or groin areas should only be targeted when Officers are defending themselves from violent attacks. These areas are sensitive to mechanical injury (such as crushing to the trachea or testicles, if applied forcefully). However, these areas have proven to be highly effective targets. f. The Taser X26 should generally, not be used under the following conditions, unless exigent circumstances exist that can be clearly articulated: 1) Handcuffed or Wrapped persons unless they are actively resisting and pose an immediate threat to Officers or other innocent bystanders. 2) Passively resisting persons or to awaken unconscious or intoxicated individuals. 3) Persons in physical control of a moving vehicle, such as an automobile, truck, motorcycle, ATV, bicycle, or scooter. 4) Persons known to have been exposed to or come into contact with flammable liquids. 5) Flammable or explosive environment (clandestine labs). 6) When the subject is in a position where a fall from a significant height or into a pool / body of water may cause serious physical injury or death. 7) Visibly pregnant persons or persons with known medical conditions which would preclude its use. 8) The person is the extremes of age (very young or very old) or physically disabled. Page 11 of 19
12 g. Taser X26 Post-Deployment Responsibilities After any intentional Taser X26 deployment, whether striking a subject or not, the officer shall: 1) When any person is contacted with the Taser X26 ensure the subject is medically cleared by medical personnel at a pre-designated medical facility prior to booking. Advise medical and jail booking personnel of the Taser X26 deployment, the number of times, and the observed effects. 2) Notify a Supervisor as soon as practical. 3) Collect and book as evidence any discharged cartridges, and a sampling of the AFID (Anti-Felon Identification). 4) TASER PROBES: Probes from the Taser X26 may be removed by EMS/medical personnel or certified users trained in removal of the probes. Probes shall be inserted point down into the expended TASER cartridge for transporting to Property & Evidence. At Property & Evidence the probes shall be disposed of in the SHARPS container as a biohazard. 5) Fully document the circumstances of the Taser X26 deployment in a Modesto Police report and Use of Force Memo. The serial number of the Taser X26 shall be included in the report. 6) Photograph the areas where the Taser X26 probes contacted the subject and any additional injuries observed or sustained during the arrest process. 7) In the event of an unintentional discharge of the Taser X26 in circumstances where no report is written, a brief memo outlining the circumstances must be submitted to the immediate Supervisor or Watch Commander on duty prior to securing a replacement cartridge. Appropriately dispose of the expended cartridge. Page 12 of 19
13 8) Damaged or inoperative cartridges shall be returned in exchange for a replacement cartridge. 7. Impact Weapons: This force option is considered to be Less Lethal. They are tools that an Officer could use as a defensive weapon for his/her protection, or to overcome resistance. Injuries from Impact Weapons are more probable than with other lower force options because of the blunt force trauma effects. The head, neck, spine, groin, or liver / spleen / kidney areas should not be deliberately targeted with Impact Weapons unless the circumstances are that of a Deadly Force situation. The following Impact Weapons are authorized for use by the Modesto Police Department: a. Batons (Straight, Side-handle, Expandable, Riot) b. Personal Body Weapons (hands, feet, knees, elbows, etc.). c. Flashlight The flashlight shall be used as an alternative emergency impact weapon only. An Officer may use the flashlight to fend off an attack in circumstances where he/she is attacked without warning. The Officer should attempt to use other more effective Impact Weapons as soon as practical in these situations. d. Bean Bag round (12gauge) The 12gauge Bean Bag round is considered a Less Lethal, Long-range Impact Weapon: 1) At distances of 5 to 20 yards and the target selection should be based on the manufacturer's target zone chart. 2) At distances of less than 5 feet, extreme caution should be exercised prior to deployment due to the possibility of a fatal outcome. 3) The optimal range for the CTS Super Sock is 5 to 20 yards. Page 13 of 19
14 4) The 12 Ga. Bean Bag rounds should never be deployed against a woman who is known to be or visibly pregnant. 5) Requirements prior to deploying a Bean Bag Round: a) In circumstances permitting where tactically feasible, the Officer deploying the Bean Bag should call out BEAN BAG at least once, loud enough for others to hear, prior to deployment. b) Whenever possible, the Officer in Charge (OIC) shall formulate a plan, prior to deployment including, but not limited to: i) An arrest team to take the suspect into custody. ii) A cover team to provide protection for the Bean Bag operator and the arrest team. iii) Alternative force options should be in place and/or considered should the use of the Bean Bag round fail. Bean Bag Gun Post-Deployment Responsibilities: After any intentional Bean Bag gun discharge, whether striking a subject or not, the officer shall: 1) Notify a Supervisor as soon as practical. 2) If any person is struck by a bean bag round, ensure the subject is medically cleared by medical personnel at a pre-designated medical facility prior to booking. Advise medical and jail booking personnel of the bean bag deployment, the number of times the person was struck, and the observed effects, if any. 3) Photograph the areas where the bean bag round contacted the subject and any additional injuries observed or sustained during the arrest process. Page 14 of 19
15 4) Fully document the circumstances of any bean bag gun discharge in a Modesto Police Report and Use of Force memo. E. Deadly Force: (Lethal Force) 5) In the event of an unintentional discharge of the bean bag gun in circumstances where no report is written, a memo outlining the circumstances must be submitted to the immediate Supervisor or Watch Commander. 6) Collect and book as evidence any discharged bean bag round(s) that is recoverable. The highest level of force that can be used. It includes any weapon, instrument, device, physical power or strength, which, if used in a deadly manner, could cause serious physical injury or death. 1. It is the policy of the Modesto Police Department that an Officer will use only that force which reasonably appears to be necessary to accomplish lawful objectives. Within that framework, officers of this department may resort to the use of a firearm in the performance of their official duties: (1.3.1)(1.3.2) a. As a means of self defense when the Officer has reasonable cause to believe he/she is in imminent danger of death or serious physical injury; or b. In defense of another person when the Officer has reasonable cause to believe the other person is in imminent danger of death or serious physical injury; or c. To prevent a crime in which human life is in serious jeopardy as result of a suspect s action; or d. To apprehend a fleeing suspect for a crime involving the use or the threatened use of Deadly Force F. Firearm: The use of firearms is addressed in the Use of Firearms General Order G. Vehicle: The use of Legal Intervention on a suspect vehicle is prohibited, except as set forth below: 1. A police vehicle may be used to conduct a Legal Intervention maneuver on a suspect or suspect s vehicle, when the suspect and or suspect s vehicle poses a clear and imminent threat of serious Page 15 of 19
16 physical injury or death to a citizen or another Officer and it appears reasonably necessary to the Officer that he/she must use his/her vehicle to prevent the suspect, or suspect s vehicle from inflicting harm, as set forth herein, to a citizen or another Officer. 2. The use of a police vehicle for Legal Intervention on a vehicle shall be reported to the Watch Commander/Unit Lieutenant immediately. The Watch Commander/Unit Lieutenant shall evaluate the circumstances to determine the appropriate level of review. 3. Depending on the circumstances, such intervention may be considered a Deadly Force option, as outlined above. 4. The use of a vehicle for Legal Intervention with a pedestrian will normally be considered Deadly Force. If the use of Legal Intervention is considered a Deadly Force option, the Internal Affairs Unit will initiate an administrative review. VII. REQUIREMENTS AFTER USE OF FORCE: A. Field Responsibility 1. Medical aid shall be obtained for subjects who have sustained injury, express a complaint of pain of injury or who have been rendered unconscious. (1.3.5) Medical aid may include, but is not limited to: a. First aid for minor injuries by on-scene Officers b. Treatment by on-scene paramedics/firefighters c. Medical clearance by a medical facility. 2. The Watch Commander and Officer s Immediate Supervisor shall be notified of the incident as soon as possible. 3. If the subject is booked, Officers shall advise the custodial staff of the type of force that was used and the location on the subject s body that was affected. This notification shall also include the type of medical treatment rendered if any. 4. If a subject is exposed to a Chemical Agent, thoroughly flush the contaminated area with cold water and expose them to fresh air. If the subject experiences abnormal adverse reactions to the Chemical Agent, then the Officer shall transport the subject to a Page 16 of 19
17 medical facility or summon medical aid depending on the circumstances. (1.3.5) B. Supervisor Responsibility 1. In addition to the police report, all incidents involving the use of force shall be thoroughly documented in a Use of Force memorandum by checking the appropriate boxes. 2. Supervisors will ensure that all personnel under their command are familiar and in compliance with this Use of Force General Order. 3. The Supervisor in charge will review the police report and Use of Force memorandum. If any training issues are discovered it is the responsibility of the responding supervisor and the officers immediate supervisor to ensure appropriate training is received. The supervisor should also document the training issue in the officers working file. (1.3.7) 4. Whenever possible, an officer should audio/video record the suspect interview with the supervisor present. A copy of the recording shall be booked into evidence and an additional copy shall be attached to the Use of Force checkbox memorandum. (1.3.7) 5. When a use of Deadly Force results in serious physical injury or death of a subject in police custody: a. The Watch Commander shall notify the Operations, Support, and Investigations Division Commanders, Duty Chief, Assistant Chief and the Chief of Police. b. The Internal Affairs Unit shall conduct an administrative investigation into the circumstances of a serious physical injury or death. c. The Crimes Against Persons Unit should conduct an investigation when use of Deadly Force results in serious physical injury or death. 6. Any employee, whose action or use of force results in a death or serious physical injury, shall be removed from line duty assignment pending an administrative review. The completion of a use of force review in the field by the supervisor is considered an administrative review that will later be documented and attached to the officer s use of force form. (1.3.8) Page 17 of 19
18 VIII. REPORTING USE OF FORCE: A. Every use of force shall be reported and documented, other than voluntary submission to arrest or overcoming passive resistance. (1.3.6) B. Supervisory notification shall be made as soon as practical following the application of force which, at the time, appears likely to have caused physical injury. C. A Use of Force memorandum shall be completed and the appropriate boxes checked or filled in as specified on the Use of Force Form. Each Officer participating in the application of use of force shall submit his/her own individual police report detailing his/her use of force. When the WRAP is the only force utilized it should be indicated on the face of the Use of Force form at the top, as a WRAP ONLY in bold block print. This form should not have any narrative. When the TaserX26 is used during encounters with vicious animals, the animal deployment box on the Use of Force Report should be checked. This form should not have any narrative. D. The use of force shall be described in detail in the appropriate report depending on the nature of the incident, (e.g. arrest report, crime report, police report). E. Officers shall document the circumstances, which led to the use of force and any notable injuries to themselves or the suspect(s) in the appropriate report depending on the nature of the incident, (e.g. arrest report, crime report, police report). F. The report shall also include any medical treatment obtained for the suspect or Officer and any evidence relative to the use of force. (1.3.5) G. Photographs 1. Any observable injury sustained by the Officer or suspect or any other individual should be photographed. 2. A photograph of the full body and the area of the body where force was applied should be taken. 3. A photograph of the full body should be taken if possible if the prisoner is non-combative when a WRAP is removed. 4. It should be documented if a prisoner refused to be photographed. Page 18 of 19
19 IX. ANNUAL ANALYSIS (1.3.13) An annual analysis will be conducted by the Internal Affairs Unit of all incidents whereby employees have caused or are alleged to have caused death or injury to another, have applied physical force upon another, or have intentionally or unintentionally discharged a firearm. The purpose of this analysis is to determine any patterns or trends that could indicate training needs and/or policy modifications. BY ORDER OF: Michael G. Harden Chief of Police OPR: COP Drafter: J. Broumas/Carlos Castro/Mike Hicks Replaces: General Order 1.06 dated General Order 1.06 dated General Order 1.06 dated General Order 1.06 dated General Order 1.06 dated General Order 1.06 dated General Order 1.06 dated General Order 1.06 dated General Order 1.06 dated General Order 1.06 dated General Order 1.06 dated General Order 1.06 dated General Order 1.06 dated General Order 1.06 dated Index as: Bean Bag Carotid Restraint Chemical Agents Controlling Force Deadly Force Force Options Impact Weapons TaserX26 Use of Force Weaponless Force Wrap Page 19 of 19
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