Penal Code §835 limits the restraint authority of any person making an arrest. The standard is:

Explanation

Penal Code §835 states that the person arrested 'may be subjected to such restraint as is reasonable for his arrest and detention.' Reasonableness is judged objectively from the totality of circumstances and is independent of the arrestor's subjective intent (b). Options (c) and (d) describe escalation models that would routinely produce excessive force. The §835 standard applies to all arrestors, peace officer and private alike, although peace officers also have additional statutory protections under §835a and Graham v. Connor's objective reasonableness test.