Use and Abuse of Lasers and the Need for Reform (2011) 56 Vill. L.Rev. 363, 384-385 [pointing out that the Federal Law Enforcement Training Center (FLETC), the national training institute that developed the use-of-force continuum, has made clear that, because of the formulaic nature of the continuum, it “directly conflicts with” Graham’s conception that “ ‘reasonableness under the Fourth Amendment is not capable of precise definition or mechanical application’ ”, and as a result, FLETC has “done away with the use-of-force continuum” in its own training materials, although many law enforcement agencies around the country still use some form of the continuum in their training programs.].) 15 Venegas v. County of Los Angeles (2004) 32 Cal.4th 820, 839-840 [11 Cal.Rptr.3d 692, 87 P.3d 1] (<HOLDING>); see Mendoza, supra, 206 Cal.App.4th at page
recognizing availability of qualified immunity defense to  1983 claims asserted in the california courts holding qualified immunity defense unavailable to the united states in ftca action holding that qualified immunity is an affirmative defense that must be pled by the official who claims it holding that defendants are not entitled to qualified immunity holding that in california the oneyear statute applies to a  1983 action