Holding: Because it is unclear in this excessive force case whether the Eighth Circuit incorrectly thought the use of a prone restraint is per se constitutional so long as an individual appears to resist officers’ efforts to subdue him, the U.S. Court of Appeals for the 8th Circuit’s judgment is vacated, and the case is remanded to give the lower court the opportunity in the first instance to employ the careful, context-specific analysis required by this court’s excessive force precedent.
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