Tasers are a double-edged sword. In some circumstances, a police officer’s deployment of her Taser may be a valuable alternative to the use of deadly force. Tasers, however, can inflict excruciating pain and serious injury, and even cause death.

During the past 15-20 years, large numbers of federal court §1983 complaints have been filed alleging that a police officer’s deployment of her Taser constituted excessive force in violation of the plaintiff’s Fourth Amendment rights. These filings have generated a very large body of decisional law evaluating the reasonableness of Taser force. The author has been carefully tracking, summarizing, and evaluating these decisions. Martin A. Schwartz, “Section 1983 Litigation: Claims and Defenses” §3.12[D][3][p] (Wolters Kluwer Law and Business 4th ed. 2018) (hereafter Claims and Defenses). Despite this vast body of decisions, “the objective reasonableness of the use of Tasers continues to pose difficult challenges to law enforcement agencies and courts alike … .” Estate of Armstrong v. Village of Pinehurst, 810 F.3d 892, 909 (4th Cir.), cert. denied, 137 S.Ct. 61(2016).