Liability Constraints on Human Restraints

by Michael A. Brave, Esq., M.S., C.P.S., C.S.T.
and John G. Peters, Jr., M.S., M.B.A.
(Copyright 1993 by the authors. All rights reserved.)

After a large Southern police department spent several million dollars to settle a handcuffing lawsuit, many police administrators, trainers, and attorneys focused on handcuff and restraint training, equipment, and policies. The lawsuit focused on the officer's failure to double-lock the handcuffs, after he handcuffed a doctor. The doctor suffered extreme nerve damage to his wrists, leaving him unable to continue his employment as a neurosurgeon. The focus of this article is to raise your awareness about restraining people, whether it's with metallic or plastic restraints.

Officers routinely restrain people. Sometimes they will use their hands, which often leads to an arrest and the use of handcuffs and/or other types of restraints. This use of restraints can generate liability, both civil and criminal. But we seldom think about handcuffs and restraints getting us into trouble. In fact, many law enforcement administrators, supervisors, and officers narrowly define liability to be the "liability" of being sued by a plaintiff in a civil lawsuit. However, liability has "been referred to as of the most comprehensive significance including almost every character of hazard or responsibility, absolute, contingent, or likely."(1) This broader definition of liability literally means "risk". So what are the "risks" of using restraints and how can these risks be controlled and/or minimized? These are some of the issues we will address. But first, a couple definitions.

For our purposes, restraints can include: metallic handcuffs-hinged or chain, non-metallic handcuffs, thumbcuffs, body wraps (e.g. the Emergency Response Belt ®), waist chains, gang chains, hobbles, seat belts, transport belts, leg braces, single-use disposable restraints (Flex-Cufs ®, Bingold Tuff-Cuffs ®, Safe-T-Cuffs ®, etc.), restraint bags, handcuff blocks, nylon straps/restraints, etc.

Also, generally the liability associated with restraints can include: civil liability, criminal liability, administrative consequences, workers' compensation costs, negative public/media impact, etc.

The Need To Restrain

Officers generally restrain people for three general reasons: (1) to protect the officers, (2) to protect the restrained person, and (3) to protect others from the restrained person. Restraining a person gives the officer greater self-protection and control. When an officer fails to restrain a person, or restrains him/her improperly (assuming the officer has a legal right to restrain the person), the person could injure the officer.

Officers also restrain people to protect the restrained person. If the person is in custody, the officer has an obligation to protect the person. People are also restrained to prevent them from self-injury (e.g., suicidal persons, confused Alzheimer victims, and emotionally disturbed persons). Restraint also includes the use of vehicle seat belts and harnesses which are used to minimize injury to the person during vehicle transport.

If officers fail to restrain someone (who the officer has a legal right to restrain) the unre- strained or improperly restrained person could injure an innocent person or destroy property or evidence. If these injuries and property destruction occur at a time when the officer should have had the person under control, the officer and his/her employer could be liable.

The basic risks associated with an officer restraining people can include officer/third party injury, property damage, plus civil and/or criminal liability. Let's first examine an injury to the restrained person by the improper application or use of the restraints. Either the handcuffs are placed on the person too tightly; the officer fails to double lock the handcuffs and the cuffs are inadvertently or intentionally tightened causing injury to the persons's wrists; or the handcuffs remain on the person for an unreasonable period of time.

There can also be negative consequences if the officer fails to properly restrain the person. If the officer handcuffs the prisoner in the front and the person begins a fight with the officer, the person and/or the officer may be injured. There have also been instances where a person who was handcuffed in front jumped into a squad car and drove away. Many times a chase ensues resulting in the handcuffed person being injured. Recently, in Rio Rancho, New Mexico, a handcuffed prisoner stole the police car, leading officers on a frenzied and embarrassing pursuit of their car and prisoner. Negative consequences can also develop if the officer fails to use vehicle restraints and the person is injured.

Officers can also be injured if the person is improperly restrained by the arresting officer. This includes being exposed to bloodborne pathogens during the restraint process.

Lastly, innocent third parties may be injured , if the officer fails to restrain or properly restrain the person.

These "risks" can reveal themselves as medical expenses for injuries to officers or the person. Administrative (disciplinary) sanctions for violation of departmental policy in the proper use of re- straints. Federal civil rights or state negligence actions for unreasonable seizure or excessive use of force. And, the unthinkable, Federal or state criminal actions for constitutional rights violations, assault, battery, false imprisonment, excessive use of force, etc. But the focus is not solely on the officer.

Supervisors, command staff, agency directors, plus the governmental entity may also become the target of litigation. For example, federal civil rights liability may attach to the supervisor, the administrator, or the municipality if the supervisor was "deliberately indifferent", or if the moving force behind the suspect's injuries (caused unconstitutionally) was an unconstitutional policy or custom of the entity. Aside from the financial costs, there are psychological costs, not to mention the negative media impact. All of this can create a negative relationship between the administrator and the controlling governmental council.

Restraints Can Be Deadly Force

If an officer over-tightens, fails to double-lock, or leaves handcuffs on a person for an extended period of time, the person can be severely injured. This type of injury is usually referred to as "handcuff neuropathy." Handcuff neuropathy, similar to carpal tunnel syndrome, is damage to the person's radial, ulnar, and/or median nerves caused by the compression of the handcuffs. This nerve damage can manifest itself as pain in the wrist, hand, and/or fingers; loss of strength and weakness of grip; numbness; loss of flexation; diminished light touch sensation; and tingling sensation in fingers(2). This nerve damage can be long term or permanent. Since such an injury is usually classified as "serious bodily harm", it can be argued that the officer used deadly force.

Deadly force is force that is intended or likely to cause death or serious bodily harm.(3) Serious bodily harm or serious physical injury is an 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.(4) Since the improper use or application of handcuffs can cause long- term loss or impairment of the functioning of the hands, this is a serious bodily injury. If the officer knew, or should have known, that his/her manner of application of the handcuffs could cause serious injury, and the person was seriously injured by the application of the handcuffs, then the officer has used deadly force on the subject. If the officer's use of deadly force was not "objectively reasonable" then the use of deadly force was excessive and in violation of the person's Fourth Amendment rights.

Restraint Standards

In order to minimize or avoid liability in the use of restraints, an officer must have a legal basis for the use of the restraints. This legal basis and use standards are created by law and the officers use of restraints is controlled by Federal law, state law, county/municipal ordinances, departmental policy, manufacturer instructions and specifications, any pertinent collective bargaining agreement, and any collateral requirements (e.g. the OSHA Bloodborne Pathogens Standard). For example, an officer sees a person standing next to a building. Since the person does not fit the neighborhood "profile", the officer asks him his name and for ID. The man begins to walk away. In a flash, the officer knocks him down, and then handcuffs him. Other than the "Contempt of Cop" charge, there is no legal basis to arrest and handcuff this person. Now, let's look at a few relevant "federal" standards.

According to the United States Supreme Court, an officer's use of force (against a "free citizen") must be objectively reasonable, based upon the totality of the circumstances known to him/her at the time. Hence, an officer's use of restraints must be in compliance with federal case and statutory law. In the normal restraint of a person as the result of a lawful temporary detention or arrest, the restraint used by the officer will be considered a use of force. Any use of force upon a free citizen by a law enforcement officer is governed by the Fourth Amendment's "objective reasonableness" test(5). The officer must be objectively reasonable in the application of the restraints - use of force. This reasonableness analysis contemplates careful consideration of the facts and circumstances of the incident, including: (1) the severity of the crime at issue, (2) whether the suspect poses an immediate threat to the safety of officers and others, and (3) whether the suspect is actively resisting arrest or attempting to evade arrest by flight. These three considerations fall under the umbrella of the "totality of the circumstances" known to the officer at the time force was used.

If the officer uses more force than is objectively reasonable, the officer will violate the person's Fourth Amendment right to be free from unreasonable seizures - use of force. If the officer uses excessive (unreasonable) force, (s)he may be liable under 42 U.S.C. § 1983 for violation of the person's constitutional rights. The officer could also face Federal criminal prosecution (under 18 U.S.C. § 242 - Deprivation of Rights Under Color of Law).

If an officer violates a person's constitutional rights by the use of the restraints, his/her employer may be subject to liability, too. [see 42 U.S.C. § 1983]. Most often, it is argued by the plaintiff's attorney that the employer failed to properly provide the officer with direction (policy), training, and supervision in the use of the restraints. If a department fails to provide adequate direction (policy) in the use of the restraints and it is the department's unconstitutional policy or custom that was the driving force behind the person's constitutional injuries, then the officer's employer can be held liable for violating the person's constitutional rights.(6)

The United States Supreme Court outlined the liability associated with a department's failure to train in the case of Canton v. Harris(7). The Canton Court stated that an officer must be trained in his/her core tasks. Obviously the use of restraints would fall within the officer's core tasks. The standard set out in Canton is "deliberate indifference." If an officer constitutionally injures (using too much force through the use of restraints) a person and the officer's department was deliberately indifferent to the injured person's constitutional rights by its training and supervision of the officer, and it is this deliberate indifference in the officer's training that was the moving force causing the person's injuries, then the officer's employer may be liable to the injured person (under 42 U.S.C. § 1983).

We would be remiss if the Davis v. Mason County(8) case wasn't dovetailed into the reasonable use of restraints. In Davis the court rules that officers must be trained in the constitutional limits of the use of force. Not only must the "how" be taught, but also the "why" to use force effectively must be taught to officers. In this case, the failure to train officers in the constitutional limits of force amounted to "deliberate indifference" to the safety of the inhabitants as a matter of law. Let's now focus on state standards.

States generally follow the federal standards. However, there are exceptions. For example, some jurisdictions require that emotionally disturbed persons (EDPs) can only be restrained with leather restraints, not metallic handcuffs. If an officer were to improperly restrain an EDP with metallic restraints, (s)he would be in violation of state law. If the EDP were injured by the application of the metallic restraints, the officer may be liable for those injuries because of the standard established by state law. Before adopting any restraint policy and/or conducting a training program, the department must research state laws (statutory, case law, and administrative codes) that may create requirements for officers use of restraints. State statutes may also create requirements on vehicle restraints - seat belts.

Although unlikely, the same type of local rules and regulations may be created by county or municipal ordinance. The department should also research any local requirements before developing policy and training programs. Let's now look at some other standards.

Department policy is a standard which guides and directs officers in the proper use of restraints. A department can set restraint standards through policy, rules, and regulations. These policies can set a standard that, if violated by the officer, will allow a plaintiff to be successful in a lawsuit.(9) More about this later.

Manufacturer instructions and specifications are often cited in court when the improper use of restraints is an issue. An officer must be aware of restraint manufacturer instructions and specifications. (S)He should comply with these standards unless there is a very good - well documented - reason not to.(10) Although one restraint manufacturer's ads claim that the officer can use the product "with no training", we don't recommend it. If nothing else, training can be the buffer between you and winning a deliberate indifference claim.

Collective Bargaining Agreements might affect the type of restraint used, and possibly how it is to be used. While most policies regarding restraints would be at management's discretion, it may still be wise to consider the input of the officers, supervisors, and training officers, before implementing any policy. The choosing and implementation of restraint equipment may be a subject of mandatory bargaining.(11)

Other Collateral Issues

In addition to the above requirements, departments must also provide guidance and training in collateral areas relating to the use of restraints. These areas will include restraining confused, mentally disturbed individuals, or the requirements of the OSHA Bloodborne Pathogens Standard.(12) Due to space constraints, only the OSHA Bloodborne Pathogens Standard will be highlighted.

Effective March 6, 1992, the OSHA Bloodborne Pathogens Standard(13) became law in 23 states. Voluntary compliance has been requested of the Governors of the remaining 27 states. Agencies must provide their officers with guidance, training, inoculations, and personal protective equipment related to bloodborne pathogens exposure. Under the Standard, contaminated(14) surfaces and equipment must be properly decontaminated(15). This means that if bodily fluids (blood, urine, saliva, etc.) are on the back seat of the squad car, on the handcuffs, or other restraints, the officer must decontaminate(16) the surface(17) and equipment before re-use(18). If the officer cannot immediately decon- taminate the articles (s)he must treat them as "regulated waste(19)" and mark them accordingly. The Standard has many requirements and should be fully researched prior to developing restraint policies and training programs.

Action Plan For Risk Reduction

Here are a few steps which you, the administrator, can take to immediately lower or eliminate restraint risk. These are:

• Only Use handcuffs that are NIJ Approved - The National Institute of Justice's (NIJ) Technology Assessment Program Information Center (TAPIC) has tested and established standards for double-locking metallic handcuffs(20). If the department, or its officers, choose not to use NIJ approved handcuffs and a lawsuit is commenced involving handcuffing restraint. The plaintiff is sure to raise the issue of lack of NIJ approval.
   
• Prohibit the use of thumbcuffs - First, the National Institute of Justice does not recommend the use of thumbcuffs. Thumbcuffs either will be too loose and the restrained person can easily remove them or the cuffs will be tight enough to control the subject and will be so tight that injury to the thumbs can be caused - "peripheral vascular disorders".
   
• Discourage hog-tying people (or placing them in postures that hamper respiratory action) - "Positional asphyxia occurs when the position of the body interferes with respiration, resulting in asphyxia."(21) "Positional restraint has been known to kill restrained individuals. If a person is placed in a position that impedes his/her breathing the person can die from asphyxiation. Death can occur in as little as five (5) minutes.
   
• Direct officers to always check restraint tightness - In order to avoid handcuff injuries (handcuff neuropathy) caused by overtightening the cuffs, the tightness of the cuffs must be checked prior to double-locking. Contemporary training programs instruct officers to use the "tip of the index finger test". That is, "after [the officer has] applied the handcuffs [(s)he] should be able to slip the tip of [his/her] index finger under the handcuffs, on the top, bottom, and sides."(22) Reinforcing this, the Flex-Cuf ® Training Manual states that: "When drawing the restraint up, put your index and middle finger inside and up against head, with thumb on the inside of the restraint. Draw strap up until strap comes in contact with your finger. Your fingers will be between the restraint and the subject's wrist. This will prevent over tightening. Be sure it's tight enough to prevent escape."(23)
   
• Direct officers to always double-lock metallic restraints - Handcuffs must be double-locked as soon as practicable after their application. If handcuffs are not double-locked, they may be tightened accidentally, or intentionally, by the restrained person. This applies to other restraints, too. If restraints become too tight, the restrained person can be severely injured, triggering liability.
   
• Direct officers to only use restraints that are allowed by state law or policy - e.g. use of metallic restraints on EDPs where state law mandates the use of leather restraints.
   
• Direct officers to give prompt attention to complaints that the cuffs are too tight - Even after using the "tip of the index finger test" and double-locking the cuffs, if the restrained person complains that the cuffs are too tight the officer should stop (if reasonably possible) and check the tightness of the cuffs. Even if the cuffs are properly applied the person could still have placed pressure on the cuffs or the person could have turned their hand within the cuff and caused constriction on part of the hand. If upon checking the cuffs the officer finds that the cuffs are at the appropriate tightness and there does not appear to be a problem the officer need not loosen the cuffs. However, the officer should document in his/her report that upon complaint the cuffs were checked.
   
• Direct officers to decontaminate restraints as soon as possible - If the restraints become contaminated with bodily fluids, decontaminate the restraints as soon as possible as dictated by the OSHA Bloodborne Pathogens Standard.

Should All Prisoners Be Restrained?

Departments must provide direction (policy), training, and supervision on proper restraint procedures in order to minimize liability. Departmental policy must provide officers with the basic framework of when and how to use restraints. Before policy can be generated the department must thoroughly research applicable laws and regulations regarding restraint in their jurisdiction.

When discussing restraint policy one issue is whether the restraint of people should be discretionary or mandatory. Mandatory restraint policies direct the officer to handcuff and/or restrain everyone in custody. Conversely, discretionary restraint policies give the officer a set of guides to aid the officer's decision as to whether to handcuff and/or restrain a given individual. Either choice has some drawbacks. The mandatory handcuff policy supports the idea of officer safety. However, the mandatory policy eliminates any discretionary immunity shield the officer may have had under a discretionary policy. The mandatory policy also opens the department up to criticism when an officer handcuffs a fifty-five (55) year old Catholic nun to transport her to the station to post bond for a speeding ticket.

The discretionary policy assists in maintaining the officer's discretionary immunity, but can create allegations of discrimination against the officer and the department. Minorities, for example, may argue that since the decision to handcuff is discretionary the officer only handcuffs African-Americans, Hispanics, or females but does not handcuff Caucasian males. Such a policy may also expose the officer and the department to liability if the officer fails to handcuff a suspect and the suspect later injures the officer (workers' compensation costs), injures a third party, or destroys property (e.g., the unrestrained suspect steals a squad car and leads the officers in a high speed chase).

Whether the policy is mandatory or discretionary, the policy must take into account sick, injured, pregnant, and disabled persons.(24) And officers must be instructed to follow the adopted policy. Deviation from the policy may invalidate it, or create a "custom" or "practice", exposing both the officer and the agency to liability.

Restraint Equipment

After policy parameters have been established the department must acquire suitable restraint equipment. The department may wish to acquire several different types of restraints for the different situations the departmental staff can foresee. The department may want NIJ approved metallic restraints, disposable restraints, body wraps, nylon leg restraints, belly chains, leg chains, etc.

And Don't Forget Training

Once departmental policy has been established and restraint equipment has been acquired the next step is to provide competent and well-documented training to the officers. The training must be in compliance with policy, and be job-related and situationally based. The department may wish to use a nationally known training firm to provide the training and the documentation. In addition to the restraint information listed above, the training should also include: (1) the constitutional parameters in the use of force; (2) detention, frisk and arrest law review; (3) jurisdictional/authority limitations; (4) the avoidance of placing a knee on the neck of a restrained person; (5) positional restraint considerations; (6) double locking; (7) restraint tightness; (8) restraint removal techniques; and (9) proper training in how to position seated people to relieve pressure on the hands and the handcuffs.(25)

Summary

Restraint liability "risk" can be minimized. Through knowledge, proper guidance, competent training, and supervision the various risks associated with restraints can be controlled and virtually eliminated. After all, none of us want to be reading about our agency's spending millions of dollars to compensate a victim of improper handcuffing, since it is so easily avoidable

© Copyright 1993 by Michael A. Brave and John G. Peters, Jr. All rights reserved

1. Black's Law Dictionary, 5th edition, page 823. 
2. Dorfman, Leslie J., M.D., Jayaram, Attigupam R., M.D., Handcuff Neuropathy, JAMA, March 6, 1978, Vol. 239, Mo. 10, Page 957. Levin, Robert A., M.D., Felsenthal, Gerald, M.D., Handcuff Neuropathy: Two Unusual Cases, Arch. Phys. Med. Rehabil., Vol 65, January 1984, pages 41-3. Stone, Donald A., M.D., Laureno, Robert, M.D., Handcuff Neuropathies, Neurology, Volume 41, Number 1, January 1991. Letters to the Editor, Handcuff Neuropathy, Neurology, June 1991, page 956. Technology Can Be a Pain When It Leads to Carpal Tunnel Syndrome, People, May 7, 1990, Vol. 33, No. 18, pages 127-130.
3. See generally, Tennessee v. Garner, 471 U.S. 1, 85 L.Ed.2d 1, 105 S.Ct. 1694, (1985); Pruitt v. Montgomery, 771 F.2d 1475 (11th Cir. 1985); Model Penal Code § 3.11(2) (1962); Mattis v. Schuarr, 547 F.2d 1007, 1009 n. 2 (8th Cir. 1 976)(en banc).
4. CALEA Standards, Chapter 1, Glossary, page 1-4, March 1991, revision. See also: United States v. Johnson, 637 F.2d 1224, 1246 (9th Cir. 1980). Restatement of Torts Second, Section § 63(b).
5. Graham v. Conner, 490 U.S. 386, 104 L.Ed.2d 443, 109 S.Ct. 1865 (1989)
    
6. Monell v. New York City Department of Social Services, 436 U.S. 658, 98 S.Ct. 2018 (1978).
    
7. City of Canton, Ohio v. Harris, et al, 489 U.S. 378, 109 S.Ct. 1197, 103 L.Ed.2d 412 (1989).
    
8. Davis v. Mason County, 927 F.2d 1473 (9th Cir. 1991), cert de nied, ___ U.S. ___, 112 S.Ct. 275, 116 L.Ed.2d 227 (1991).
    
9. These are not handcuff/restraint cases: Berry v. City of Muskogee, 900 F.2d 1489, 1487 (10th Cir. 1990). The court held that deficiencies in agency policy as serted by plaintiff were sufficient to support a jury finding of "deliberate indifference". DiLoreto v. Borough of Oaklyn, 744 F.Supp. 610, 623-24 (D.N.J. 1990). Having no policy at all may amount to "deliberate indif ference." Murphy v. City of Minneapolis, 292 N.W.2d 751 (Minn. 1990). State laws establish statutory privilege to use deadly force as a defense to common law battery, but not to negligence. Even where force is justified under a statute, however, "negligence" can be proven by showing an officer violated a departmental regulation governing the use of force.
    
10. See: Peters, John G., Jr. Tactical Handcuffing: for Chain & Hinged Style Handcuffs. Albuquerque: Reliapon Police Products, 1989. - (800) 423-0668. Flex-Cuf ® Restraints Training Manual, Becton Dickinson Public Safety, West Caldwell, N.J., - (800) 631-1122.
     
11. City of Iowa City v. Iowa PERB, P.E.B., Paragraph 34, 591 (Iowa) (CCH, 1985).
     
12. 29 CFR Part 1910.1030, Occupational Exposure to Bloodborne Pathogens: Final Rule, Federal Register, dated, December 6, 1991.
     
13. See: Brave, Michael A., and Peters, John G., Jr., OSHA's Occupa tional Exposure to Bloodborne Pathogens Standard: How It Can Save Your Life! Part 1 of 2, pages 28-29,37-38, 41, Police and Security News, July/August 1992, Vol 8, No. 4. Brave, Michael A., and Peters, John G., Jr., OSHA's Occupa tional Exposure to Bloodborne Pathogens Standard: How It Can Save Your Life! Part 2, Police and Security News, September/O- ctober 1992, Vol 8, No. 5.
     
14. "Contaminated means the presence of the reasonably anticipated presence of blood or other potentially infections materials on an item or surface." Federal Register, Vol. 56., No. 235, Section 1910.1030, (b).
     
15. "Decontamination means the use of physical or chemical means to remove, inactivate, or destroy bloodborne pathogens on a surface or item to the point where they are no longer capable of transmit ting infections particles and the surface or item is rendered safe for handling, use, or disposal." Federal Register, Vol. 56., No. 235, Section 1910.1030, (b).
     
16. "All equipment ... and working surfaces shall be cleaned and de contaminated after contact with blood or other potentially infec tions materials." Federal Register, Vol. 56., No. 235, Section 1910.1030, (d)(4)(ii).
     
17. "Contaminated work surfaces shall be decontaminated with an appropriate disinfectant after completion of procedures; immedi ately or as soon as feasible when surfaces are overtly contami nated or after any spill of blood or other potentially infections ma terials; and at the end of the work shift if the surface may have become contaminated since the last cleaning." Federal Register, Vol. 56., No. 235, Section 1910.1030, (d)(4)(ii)(A).
     
18. "Equipment which may become contaminated ... shall be examined prior to servicing ... and shall be decontaminated ..." Federal Register, Vol. 56., No. 235, Section 1910.1030, (d)(2)(xiv).
     
19. "Regulated Waste means ... items that are caked with dried blood or other potentially infectious materials and are capable of releas ing these materials during handling. Federal Register, Vol. 56., No. 235, Section 1910.1030, (b).
     
20. Metallic Handcuffs - National Institute of Justice Standard 0307-01, March 1982 - and subsequent updates including Consumer Product Lists.
     
21. Reay, Donald T., M.D., Fligner, Corinne L., M.D., Stilwell, Allan D., M.D., Arnold, Judy, Positional Asphyxia During Law Enforcement Transport, The American Journal of Forensic Medicine and Pathology, Vol. 13, No. 2, 1992, pages 94, full article on pages 90-97. Also see: Peters, John G., Jr., Selected Medial Implications of Handcuffing, Police and Security News, January/February 1992, Vol. 8, No. 1., pages 24-27.
     
22. Peters, John G., Jr. Tactical Handcuffing: for Chain & Hinged Style Handcuffs. Albuquerque: Reliapon Police Products, 1989, page 70.
     
23. Flex-Cuf ® Restraints Training Manual, page 6.
     
24. For more information on restraint policy: Transportation of Prisoners, Model Policy, IACP/BJA National Law Enforcement Policy Center, International Association of Chiefs of Police.
    
    Sample Restraint Policy by John G. Peters, Michael A. Brave, and John S. Farnam available from Reliapon Police Products, Albuquerque, New Mexico - (800) 423-0668.
     
25. See: Use of Handcuffs, Training Key No. 267, Training Key Volume 12, International Association of Chiefs of Police.
    
    Peters, John G., Jr., Tactical Handcuffing Part I, Police and Security News, January-February 1988, pages 6-23.
    
    Peters, John G., Jr., Tactical Handcuffing Part II, Police and Security News, March-April 1988, pages 2-19.
    
    Peters, John G., Jr., Tactical Handcuffing: Test Administrator Manual, Albuquerque, Reliapon Police Products, Inc., 1988.
    
    Peters, John G., Jr., Restraining Prisoners: A Historical View, Police and Security News, September-October 1989, pages 6-9.
    
    Peters, John G., Jr., Kubotai: New Restraint Tool, Police and Security News, July-August 1990, page 40.
    
    Peters, John G., Jr., New Restraints for the 1990's, Police and Security News, September-October, pages 12-35.
    
    Peters, John G., Jr., Tactical Handcuffing review: Standing Face to Face No. 1, Poster. Albuquerque: Reliapon Police Products, Inc., January 1991.
    
    Peters, John G., Jr., Video - Tactical Handcuffing: Part I. Video Production. M&C Productions, Santa Ana, 1986.
    
    Peters, John G., Jr., Video - Tactical Handcuffing: Part II. Video Production. M&C Productions, Santa Ana, 1986.
    
    Truncale, Joseph, J., Handcuffing and Officer Survival, Total Survival, Performance Dimensions Publishing, pages 409-21, 1993.

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