U.S. appeals court restraints use of force.

• Position: Pretrial Detention - Brief Article

Hawkins v. Comparet-Cassani, 251 F.3d 1230 (9th Cir. 2001). A convicted prisoner who had a "stun belt" placed on him, and activated, when he appeared in court for sentencing, brought a [section] 1983 action. The district court certified a class action and granted a preliminary injunction. The appeals court reversed in part and remanded. The appeals court held that the class of all persons in the custody of the county sheriff was improperly certified since the convicted prisoner could not serve as a representative for those prisoners who had not yet been convicted. The appeals court also found the district court injunction against the use of the belt...