"CASE EXAMPLE: Officer Smitts and his partner observe Delany punch somebody outside a bar and then run away. The officers give chase. When they catch up, Delany struggles and strikes at the officers in an effort to escape. While Officer Smitts applies a chokehold, the partner manages to handcuff Delany and manacle his legs. However, Officer Smitts continues to apply the chokehold for another minute, until Delany passes out.
QUESTION: Did Officer Smitts use excessive force?
ANSWER: Yes. Once Delany was shackled, there was no further need for the chokehold. However, Officer Smitts would probably be able to convince a judge or jury that his continued use of the chokehold was reasonable under the circumstances." -From, "The Criminal Law Handbook"