suggesting she was inclined toward dangerous behavior when she was upset. He also knew that she had been driving while intoxicated. The severity of the crime justified keeping McColman in handcuffs after she was arrested, especially given Doan’s knowledge that McColman could present a threat to the safety of others. See Graham, 490 U.S. at 396, 109 S.Ct. 1865. Thus, Doan’s decision not to remove McColman’s handcuffs was objectively reasonable. McColman told Doan she could not scoot into the back seat of the police ear without the use of her hands. Thus, Doan, having made a reasonable decision not to remove MeColman’s handcuffs, had to apply some force to get her into the back seat so that he could close the door and transport her to jail. See Graham, 490 U.S. at 396, 109 S.Ct. 1865 (<HOLDING>). Grabbing her by her upper arms and pulling
recognizing that an arrest requires either physical force  or where physical force is absent submission to the assertion of authority holding that a government officer has the right to use some degree of physical coercion to effect an arrest holding the use of deadly force is constitutionally permissible only if the officer has probable cause to believe that the suspect poses a threat of serious physical harm either to the officer or to others holding that an arrest may involve either 1 taking the alleged violator into exlended physical custody or 2 issuing the individual a citation and noting that when we use the word arrest in this opinion we refer to physical arrest holding to the same effect