of the officers or others, and whether he is actively resisting arrest or attempting to evade arrest by flight.’ ” Jackson v. City of Bremerton, 268 F.3d 646, 652 (9th Cir.2001) (quoting Graham v. Connor, 490 U.S. 386, 396, 109 S.Ct. 1865, 104 L.Ed.2d 443 (1989)). In this case, the appellant alleges that the officers unreasonably pointed their weapons at her, handcuffed her roughly, smashed her arm on the desk, and refused to loosen tight handcuffs. Under some circumstances, this could be excessive force. Compare Robinson v. Solano County, 278 F.3d 1007 (9th Cir.2002) (pointing a gun at suspect’s head constituted unreasonable force when no exigent circumstances existed and the defendant was obviously not armed), with Jackson v. City of Bremerton, 268 F.3d 646, 651-53 (9th Cir.2001) (<HOLDING>). However, “[n]ot every push or shove, even if
holding that excessive force claims are not subject to exhaustion requirement holding that rough handling under the exigent circumstances present was not excessive force 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 that exhaustion requirement applies to excessive force claims holding that excessive force claims are to be treated under the fourth amendment