Deadly Force was Excessive: United States v. Pagen-Ferrer.17 In a 2013 case a federal court affirmed the conviction of four San Juan, Puerto Rico police officers in the 2003 death of a handcuffed suspect the officers kicked to death. No actions were brought against the officers by Puerto Rico authorities. In 2008 the officers were indicted under federal law for perjury, obstruction of justice, and violation of the victim's civil rights. The federal court of appeals affirmed the officer's convictions and sentences ranging from 57 months in prison for one officer, to 360 months in prison for the supervising officer. Contreras v. Los Angeles18 Police investigating a drive-by shooting arrested a suspect. The suspect, who was not carrying a weapon, attempted to flee from the police. After just 20 seconds of flight, the officers shot him four times in the back. In a 2015 decision a federal court of appeals affirmed a $5.75 million judgement in a 1983 action against the officers. Deadly Force was Not Excessive Davis v. Romer19 Fort Worth, Texas po- lice officers stopped a car after observing the driver violate traffic laws. While questioning the driver, the police discovered he was wanted on several other traffic warrants. The driver refused to exit the car, and began accelerating away from the officers. One officer was standing on the vehicle's running board, and ordered the driver to stop. He refused, and started driving the vehicle towards a freeway entrance. The officer shot the driver, who died. The driver's children