California, United States of America
The following excerpt is from Lopez v. City of Los Angeles, B219499 (Cal. App. 2011):
3. Other causes of action and named defendants were dismissed from the lawsuit. We requested supplemental briefing regarding federal authority holding than an excessive force claim is not viable in a suit alleging the personal injury of a hostage. (See, e.g., Childress v. City of Arapaho (10th Cir. 2000) 210 F.3d 1154, 1157.) The parties agree that the principle expressed in Childress is not applicable to a state negligence cause of action.