the court noted that "[disorderly conduct is not a serious offense,” Fils, 647 F.3d at 1288 (citing Vinyard, 311 F.3d at 1347), and that “resisting arrest without force does not connote a level of dangerousness that would justify a greater use of force,” id. 41 . The court noted that the bystander faced charges of resisting arrest without force, he "did not ignore any verbal instructions, nor did he attempt to free himself” from the officer after the officer tazed him. Fils, 647 F.3d at 1289. 42 . Reese faced charges of “misdemeanor obstruction!, . •.] a crime of 'minor severity’ for which less force is generally appropriate.” Reese, 527 F.3d at 1274 (citing Vinyard, 311 F.3d at 1348-49). 43 . See e.g., Morse v. Frederick, 551 U.S. 393, 410, 127 S.Ct. 2618, 168 L.Ed.2d 290 (2007) (<HOLDING>); Vernonia Sch. Dist. 47J, 515 U.S. at 655-56,
holding that the first amendment does not guarantee a students right to display a message that could reasonably be interpreted as promoting drug use at a school event holding that the first amendment does not provide a right to use the ballot itself to send a particularized message holding that school officials may not limit the first amendment rights of students and teachers to freedom of speech and expression recognizing the right of students to challenge on first amendment grounds actions of school officials which circumscribe the range of ideas to which students are exposed holding that school district policy requiring that students obtain the review and approval of school officials prior to distributing any written material violated free speech rights of students