Restraint Asphyxia & Positional Asphyxia

How Restraint Kills

Restraint asphyxia can occur when the physical position of a restrained person interferes with adequate breathing. These cases require careful review of the restraint position, duration, medical findings, video, and applicable training materials.

The risk is heightened when officers:

• Place a person face-down (prone) and apply weight to the back, shoulders, or neck
• Use hobble restraint or “hogtie” positions that restrict chest expansion
• Continue compression after the person stops actively resisting
• Ignore statements like “I can’t breathe” or visible signs of respiratory distress
• Fail to roll the person onto their side once handcuffed

The Constitutional Standard

Under the Fourth Amendment, force must be objectively reasonable. Whether continued prone compression or restraint violates the Constitution depends on the full record, including control status, breathing difficulty, officer knowledge, warnings, and available alternatives. For pre-trial detainees, the Fourteenth Amendment's due process clause may also apply.

What Officers Are Trained to Know

Training materials, department policies, and in-service records may address restraint positioning, medical monitoring, and positional-asphyxia risk. We review those materials against the video, witness accounts, and medical timeline.

• CLEET Training Records: In-service training on restraint risks and positional asphyxia awareness.
• Department Policy Manuals: Written policies on prone restraint, maximum restraint duration, and medical monitoring.
• Prior Incidents: Use-of-force reports where similar techniques were used — evidence of a pattern or custom.

Evidence That May Require Review

• Body camera and surveillance footage — frame-by-frame analysis of restraint positioning and duration.
• Autopsy and forensic pathology — independent review of cause and manner of death.
• Officer training records — what the officer was taught about positional asphyxia and when.
• Dispatch and communication records — timeline of when EMS was called (or not called).

Monell Liability: The Department's Responsibility

A municipal claim under Monell generally requires proof that an actionable policy, custom, or qualifying failure caused the constitutional violation. The evidence and governing law determine whether such a claim is available.