The following excerpt is from Cortesluna v. Leon, 979 F.3d 645 (9th Cir. 2020):
And although a knee on the back is a lesser personal intrusion than beanbag rounds, it still constitutes a meaningful personal intrusion when it causes injury. LaLonde v. County of Riverside , 204 F.3d 947, 952 (9th Cir. 2000). In evaluating reasonableness, we may consider the
[979 F.3d 654]
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