Editing Use of force (section)

=== ''Payne v. Pauley'' (2003) ===
Payne v. Pauley is a case in the Seventh Federal Circuit Court of Appeals, which held that the use of force must be both reasonable and actually necessary to avoid an excessive force complaint.<ref>{{Cite web|url=https://www.policeone.com/police-products/firearms/articles/1271618-How-police-officers-can-avoid-claims-of-excessive-force/|title=How police officers can avoid claims of excessive force|access-date=May 17, 2019|archive-date=September 29, 2019|archive-url=https://web.archive.org/web/20190929135533/https://www.policeone.com/police-products/firearms/articles/1271618-How-police-officers-can-avoid-claims-of-excessive-force/|url-status=dead}}</ref><ref>Payne v. Pauley, 337 F.3d 767, (7th Cir. 2003)</ref>