by Ankeny should arise rarely and therefore would be unlikely to produce a swarm of cases involving excessive force searches. Also, officials and courts are far more competent to discern which extraordinary tactics constitute excessive force than to determine in the heat of the moment “what constituted] a reasonable wait time in a particular case” before entering' — usually a matter of calculating, wholly subjectively the appropriate number of seconds. Id. at 2166 (internal quotations and citations omitted). In fact, without any difficulty, we have in the past in a case remarkably similar to the one before us struck down, as constituting excessive force, specific tactics such as the ones used in the case before us. See, e.g., Boyd v. Benton County, 374 F.3d 773, 779 (9th Cir.2004) (<HOLDING>). Finally, on the cost side, the
holding that inquiry as to whether officers are entitled to qualified immunity for use of excessive force is distinct from inquiry on the merits of the excessive force claim holding officers punch of an inmate was not excessive force holding that ordering police officers to use excessive force in bringing a lawyer into court was a judicial act recognizing that the fourth amendment protects against the use of excessive force by police officers in carrying out an arrest holding that officers had employed constitutionally excessive force by blindly throwing a flash bang grenade into an apartment occupied by five to eight individuals