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The Supreme Court recently overturned the Ninth Circuit "provocation rule" in which the circuit court allowed liability for excessive force when an officer "intentionally or recklessly provokes a violent confrontation." However, the Supreme Court did not foreclose liability for improper tactics or injuries proximately caused by other constitutional violations. County of Los Angeles v. Mendez, 137 S.Ct. 1539 (2017). Photo: Police File

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