A Survey of Police Policy Manuals on Use of Force Against Uncooperative Arrestees: Baton Strikes, Target Areas, and Evolving Standards

With Special Focus on Bakersfield, California (2009 – 2026)

By Joseph William Baker — April 11, 2026

Table of Contents

1. Introduction
2. The Use-of-Force Continuum and Legal Framework
3. Baton Target Areas — What the Policies Say
4. Specific Body Target Areas — Detailed Analysis
   • 4.1 Head and Neck
   • 4.2 Groin
   • 4.3 Kidneys and Spine
   • 4.4 Ankles, Legs, and Peroneal Nerve
5. How Many Baton Strikes Are Appropriate?
6. When Is Force Appropriate on a Non-Compliant Subject?
7. Bakersfield, California — A Case Study
   • 7.1 The Scope of the Problem
   • 7.2 The DOJ Investigation and Stipulated Judgment
   • 7.3 Monitoring Reports and Current Status
8. Evolution of California Law (2009 – 2026)
9. Findings and Conclusions
10. Sources and References

1. Introduction

This survey examines how police policy manuals across the United States govern the use of batons and impact weapons against non-compliant arrestees. With escalating public scrutiny of police tactics, particularly following the killing of George Floyd in 2020 and the resulting wave of reform legislation, understanding the precise rules that govern when and where officers may strike citizens has never been more critical. The survey draws on published policy manuals from major police departments, the California Commission on Peace Officer Standards and Training (POST), Stanford Law School’s Model Use of Force Policy, Amnesty International, and the U.S. Department of Justice.

The central questions addressed include: What parts of the body are officers taught to target with batons, and why? Under what circumstances is force appropriate when a subject is non-compliant but not combative? How many baton strikes constitute reasonable force, and when does the line into excessive force get crossed? How have these policies evolved since 2009, particularly in California?

A particular focus is given to Bakersfield, California — a city whose police department has been under state investigation since 2016 and operated under a court-enforced stipulated judgment since 2021. Between 2016 and 2019, Bakersfield police broke bones in at least 31 people, with no officer ever being disciplined. The California Department of Justice found a “pattern or practice” of unconstitutional policing. Bakersfield thus serves as a critical case study in what happens when use-of-force policies exist on paper but fail to restrain excessive violence in practice.

2. The Use-of-Force Continuum and Legal Framework

The foundational framework governing police use of force in the United States is the use-of-force continuum, an escalating series of actions an officer may take to resolve a situation. According to the National Institute of Justice:

“Most law enforcement agencies have policies that guide their use of force. These policies describe a escalating series of actions an officer may take to resolve a situation. This continuum generally has many levels, and officers are instructed to respond with a level of force appropriate to the situation at hand.”

— National Institute of Justice, The Use-of-Force Continuum, August 3, 2009

The NIJ defines five levels on the continuum:

1. Officer Presence — No force is used. The mere presence of a law enforcement officer deters crime or diffuses a situation.
2. Verbalization — Non-physical force. Officers issue calm, nonthreatening commands, increasing volume as necessary.
3. Empty-Hand Control — Officers use bodily force, including soft techniques (grabs, holds, joint locks) and hard techniques (punches, kicks).
4. Less-Lethal Methods — Officers use less-lethal technologies including batons or projectiles to immobilize a combative person, chemical sprays, and conducted energy devices (CEDs/Tasers).
5. Lethal Force — Officers use lethal weapons, such as firearms, when a suspect poses a serious threat.

The constitutional standard for evaluating whether any use of force was excessive was established by the U.S. Supreme Court in Graham v. Connor, 490 U.S. 386 (1989). The Court held that:

“All claims that law enforcement officers have used excessive force — deadly or not — in the course of an arrest, investigatory stop, or other seizure of a free citizen should be analyzed under the Fourth Amendment and its ‘reasonableness’ standard.”

— Graham v. Connor, 490 U.S. 386 (1989)

Under Graham, the test is objective reasonableness from the perspective of a reasonable officer on the scene, not with the benefit of 20/20 hindsight. The Court identified three key factors: the severity of the crime at issue, whether the suspect poses an immediate threat to the safety of officers or others, and whether the suspect is actively resisting arrest or attempting to evade arrest by flight.

California has further refined these standards. In 2019, the state enacted Assembly Bill 392 (the California Act to Save Lives), which amended Penal Code sections 196 and 835a to change the deadly force standard from “reasonable” to “necessary.” Under the new standard, officers may use deadly force only when they “reasonably believe, based on the totality of the circumstances,” that it is necessary to defend against an imminent threat of death or serious bodily injury. The law also requires officers to use de-escalation techniques, proportional tactics, and available alternatives before resorting to deadly force when feasible.

3. Baton Target Areas — What the Policies Say

Across the United States, there is a broad, near-universal consensus in police policy manuals about which parts of the body are acceptable targets for baton strikes and which are not. The Stanford Law School Model Use of Force Policy, one of the most comprehensive modern frameworks, provides a clear statement:

“Officers must strike only the arms or legs and avoid strikes to the head, neck, sternum, spine, groin, or kidneys, absent justification for use of Deadly Force.”

— Stanford Law School, Model Use of Force Policy, Chapter 8: Batons, November 11, 2022

The Baltimore Police Department is even more explicit, classifying these strikes not merely as inappropriate but as lethal force:

“Strikes to the head, neck, sternum, spine, groin, or kidneys are Deadly Force/Lethal Force.”

— Baltimore City PD, Policy 1111 BATONS

The U.S. Customs and Border Protection policy echoes this classification:

“Intentional strikes with the baton to the head, the neck, the face, the groin, the solar plexus, the kidneys, or the spinal column” are classified as deadly force applications.

— CBP Use of Force Policy, January 2021

The COPS Office of the U.S. Department of Justice provides the rationale:

“During non-deadly force incidents, officers will use reasonable care to avoid striking suspects on the head, neck, sternum, spine, groin, or kidneys, as these areas may result in serious injury or death.”

— COPS Office, Use of Force Policy

Similarly, the San Francisco Police Department General Order 5.01 states:

“Officers may not strike [the] head, neck, face, throat, spine, groin or kidney.”

— SFPD DGO5.01, “Use of Force Policy and Proper Control of a Person”

Amnesty International, in its 2022 position paper on striking weapons, took a stronger stance:

“Injury or even death (such as strikes the head, neck, spine, throat or groin area) should be prohibited, except in the extreme situation of a threat of serious injury.”

— Amnesty International, Batons and Other Handheld Kinetic Impact Weapons, 2022

The convergence across these diverse sources — from law schools to federal agencies to international human rights organizations — is striking. The head, neck, spine, groin, and kidneys form a universally recognized category of prohibited target areas for baton strikes, except in circumstances where deadly force is legally justified. By contrast, the arms and legs are the universally recognized permitted target areas for non-deadly baton use.

4. Specific Body Target Areas — Detailed Analysis

4.1 Head and Neck

Strikes to the head and neck are classified as deadly force across virtually every policy manual in existence. The head contains the brain, skull, eyes, ears, nasal cavity, and jaw. A baton strike to the head risks skull fracture, traumatic brain injury (TBI), intracranial hemorrhage, facial fractures, dental avulsion, and loss of vision or hearing. Strikes to the neck risk damage to the cervical spine, tracheal collapse, carotid artery dissection, and airway compromise, any of which can be rapidly fatal.

No major police policy permits head or neck strikes with a baton except when the officer is lawfully justified in using deadly force — that is, when the subject poses an imminent threat of death or serious bodily injury to the officer or others. This classification reflects the recognition that a blow from a metal or composite baton to these areas carries an unacceptably high risk of death or permanent disability for a non-deadly force encounter.

4.2 Groin

The groin is universally listed among prohibited target areas. The groin contains the external genitalia, femoral artery and vein, inguinal lymph nodes, and the ilioinguinal and iliohypogastric nerves. A baton strike to this area can cause testicular rupture or torsion, internal hemorrhage, nerve damage resulting in chronic pain, and incapacitating shock. The pain from a groin strike can be so severe as to cause nausea, vomiting, and fainting.

As with head and neck strikes, groin strikes are classified as deadly force applications. The rationale is that the vulnerability of these structures and the severity of potential injury make them inappropriate targets for any level of force below lethal force.

4.3 Kidneys and Spine

The kidneys are paired organs located in the retroperitoneal space on either side of the spine. They are highly vascular organs receiving approximately 25% of cardiac output. A baton strike to the kidney area risks renal contusion, laceration, or rupture, which can cause life-threatening internal bleeding and shock. Kidney injuries may not present immediate symptoms, making them particularly dangerous in a custody setting where medical attention may be delayed.

The spine houses the spinal cord, the primary neural pathway between the brain and the body. Baton strikes to the spine risk vertebral fracture, spinal cord compression or transection, and permanent paralysis. Injuries to the thoracic and lumbar spine can result in paraplegia; injuries to the cervical spine can result in quadriplegia or death.

Both the Baltimore PD and CBP policies explicitly classify kidney and spine strikes as deadly force. The COPS Office guidance directs officers to “use reasonable care to avoid” these areas during non-deadly force incidents.

4.4 Ankles, Legs, and Peroneal Nerve

The lower extremities — legs, ankles, and feet — represent the primary permissible target area for baton strikes in non-deadly force encounters. This is not arbitrary; there is a specific tactical rationale based on achieving temporary motor dysfunction with minimal risk of serious or permanent injury.

The Peroneal Strike

The most commonly taught baton technique targeting the lower extremities is the peroneal strike (also called the common peroneal nerve strike). According to the Wikipedia entry on the technique:

“A peroneal strike is a temporarily disabling blow to the common fibular (peroneal) nerve of the leg, just above the knee. The attacker aims roughly a hand span above the exterior side of the knee, towards the back of the leg. This causes a temporary loss of motor control of the leg, accompanied by numbness and a painful tingling sensation from the point of impact all the way down the leg, usually lasting anywhere from 30 seconds to 5 hours in duration. The strike is commonly made with the knee, a baton, or shin kick, but can be done by anything forcefully impacting the nerve.”

— Wikipedia, “Peroneal strike”

The St. Louis Metropolitan Police Department Use of Force policy states:

“The primary goal of the baton/nightstick, when used as non-deadly force, is to create a temporary muscle or motor dysfunction in a subject’s arms or legs.”

— St. Louis Metropolitan Police Department, Use of Force Policy

The Indiana Uniform Statewide Defensive Tactics Training Program identifies the common peroneal and femoral nerve motor points as “primary target areas.” The California POST Learning Domain 20 curriculum and the Albany (CA) Police Department Impact Weapons training materials similarly direct baton strikes to “target areas of hands, arms, lower abdomen, legs or feet.”

Ankle Strikes

Lower leg and ankle strikes are sometimes employed for pain compliance when a subject is on the ground and resisting. However, many modern policies now restrict or prohibit strikes on grounded subjects. The Stanford Model Policy states that officers are “prohibited from using a Baton or other Impact Weapon to strike a person who is compliant or who is exhibiting only Passive” resistance, and further prohibits striking vulnerable populations absent deadly force justification.

While the legs and ankles are permissible target areas, officers are trained to use the minimum force necessary. The goal is pain compliance or temporary motor dysfunction to achieve control, not to cause lasting injury. A baton strike to the ankle or lower leg can cause fractures, particularly in individuals with osteoporosis or other bone conditions, which has been a documented problem in Bakersfield.

5. How Many Baton Strikes Are Appropriate?

There is no universally fixed number of baton strikes that constitutes excessive force. The standard remains objective reasonableness evaluated under the totality of the circumstances, as established by Graham v. Connor. What constitutes reasonable force in one situation may be excessive in another, depending on factors such as the subject’s size, level of resistance, the availability of less-lethal alternatives, and the presence of other officers.

However, several landmark cases illustrate where courts and the public have drawn the line:

• Rodney King (1991): Approximately 33 baton strikes were delivered to King, who was on the ground and surrounded by multiple officers. The incident, captured on video, became a national symbol of police brutality and led to the acquittal and subsequent federal conviction of the involved officers. The number of strikes — far exceeding what was needed to control one man — was central to the finding of excessive force.
• Bakersfield, CA (2016–2019): As detailed in Section 7 below, baton strikes by BPD officers broke at least 45 bones in 31 people over four years. While the department found every incident to be within policy, the sheer volume of bone-breaking force raised serious questions about whether internal review was functioning as an accountability mechanism.

The Stanford Model Policy provides general guidance: officers should stop striking once compliance is achieved or the threat is neutralized. Each individual strike must be independently justified under the circumstances existing at the moment it is delivered. The Baltimore PD policy states that the baton may be used “only when deemed reasonable according to Department policy and training” and that “under no circumstances shall this weapon, or any use of force option, be used as punishment.”

Factors that officers and review boards consider in evaluating the reasonableness of baton strikes include:

6. When Is Force Appropriate on a Non-Compliant Subject?

A critical distinction in use-of-force doctrine is the difference between passive resistance and active resistance. Passive resistance refers to non-compliance without physical opposition — for example, going limp, refusing to move, or linking arms with other protesters. Active resistance involves physical efforts to resist an officer’s control, such as pulling away, bracing against attempts to be handcuffed, or assuming a defensive posture.

The Stanford Model Policy draws a clear line:

“Officers are prohibited from using a Baton or other Impact Weapon to strike a person who is compliant or who is exhibiting only Passive resistance.”

— Stanford Law School, Model Use of Force Policy, Chapter 8: Batons, November 2022

The NIJ use-of-force continuum places baton use at the “Less-Lethal Methods” level, appropriate for “a combative person.” This suggests that mere non-compliance, without active physical resistance or combative behavior, does not justify baton deployment.

California’s AB 392 (2019) further refined these standards for deadly force encounters. The law amended Penal Code § 835a to require that officers use deadly force only when “necessary” rather than merely “reasonable,” and added a duty to use de-escalation techniques, proportionality, and available alternatives before resorting to deadly force. The California POST Learning Domain 20 curriculum trains officers to use only the level of force necessary to gain control, emphasizing de-escalation as a core competency.

In practice, the application of force against non-compliant subjects varies widely. In Bakersfield, officers struck Robert Cruz Jr. with a baton while he was crouched in a fetal position behind a child’s play tunnel — a position that suggests passive, not active, resistance. In another case, a 57-year-old woman had her wrist broken while officers wrestled with her in a pile of blankets at a Greyhound bus station for suspected trespassing. These cases illustrate the gap between policy on paper and practice on the street.

7. Bakersfield, California — A Case Study

7.1 The Scope of the Problem

Bakersfield, California — the seat of Kern County, with a population of approximately 403,000 — has one of the most troubled records of police violence in the United States. The Guardian identified Kern County as having the “highest number of police killings per capita of any US county” in 2015, reporting that 79 people were killed by police in the county between 2005 and 2015.

A 2021 investigation by KQED, drawing on public records released under California’s transparency laws, revealed the scope of baton-related injuries in Bakersfield:

“Between 2016 and 2019, Bakersfield police officers used force that broke at least 45 bones in 31 people, an analysis of public records shows.”

— KQED, Bakersfield Police Broke 31 People’s Bones in Four Years. No Officer Has Been Disciplined for It., June 16, 2021

Using batons, police caused fractures in individuals accused of serious crimes and in others who were never charged at all. Specific cases documented by KQED include:

• Robert Cruz Jr. (November 2017): Stopped for a missing bicycle light. When he crouched behind a child’s play tunnel, an officer struck his arm with a baton, causing a bone to protrude through his skin. He was charged with assaulting an officer and resisting arrest.
• Cory Joe Pearson (2017): After a confrontation at a Vagabond Inn following a shooting incident, officers tackled Pearson to the ground and struck his shin with a baton twice, breaking his leg. Four years later, Pearson said he still had not recovered.
• A 57-year-old woman: Officers broke her wrist while wrestling with her in a pile of blankets at a Greyhound bus station for suspected trespassing.
• A man in Martin Luther King Jr. Park: Officers tased him and hit him with a baton, breaking his leg, for allegedly violating the city’s curfew.
• Two other bicyclists: Stopped for code violations, both suffered broken bones — one with head fractures, the other a broken leg.

Despite the severity of these injuries, the internal review process found that no officer had violated departmental policy in any of the 31 cases. BPD Sgt. Robert Pair stated:

“It’s the unfortunate reality that force is sometimes used in defense of officers and others, and that’s the world we live in. I don’t think that that is an alarming number at all.”

— BPD Sgt. Robert Pair, quoted in KQED, June 2021

Stephanie Padilla, a staff attorney for the ACLU of Southern California, disagreed sharply:

“I do think that is high, and I do think that is a really troubling number that one out of three [serious] use-of-force cases result in broken bones.”

— Stephanie Padilla, ACLU SoCal, quoted in KQED, June 2021

Seth Stoughton, a law professor at the University of South Carolina who testified for the prosecution at Derek Chauvin’s trial, reviewed the internal report on the Cruz incident and called it “woefully inadequate” to examine whether the force used was appropriate. “It does not have anywhere near the level of detail that any competent supervisor would demand to assess, even in a very cursory fashion, the incident being described,” Stoughton said.

7.2 The DOJ Investigation and Stipulated Judgment

In December 2016, then-California Attorney General Kamala Harris opened a civil rights investigation into the Bakersfield Police Department. CNN reported:

“A four-year state investigation found that the department violated the constitutional rights of residents by using unreasonable deadly force and conducting unnecessary arrests, searches, and other practices.”

— CNN, August 23, 2021

The California DOJ concluded that BPD:

• Engaged in unreasonable force, stops, searches, arrests, and seizures
• Failed to exercise appropriate management and supervision
• Used unreasonable deadly force against individuals with mental health disabilities and those undergoing a mental health crisis
• Failed to provide meaningful access to police services to individuals with limited English proficiency
• Failed to adequately maintain a meaningful program to address civilian complaints
• Lacked a comprehensive community policing program

On August 23, 2021, Attorney General Rob Bonta announced a stipulated judgment with the City of Bakersfield and BPD, describing it as an agreement that would “help make that happen” in building community trust. The five-year agreement required BPD to:

• Revise use-of-force policies to focus on necessity, proportionality, and de-escalation
• Prohibit electronic control weapons on handcuffed individuals and children
• Require officers to avoid restraining subjects face down whenever possible
• Expand use-of-force reporting to include anything above standard handcuffing
• Require supervisory investigations for all reportable uses of force
• Strengthen training, including interactive de-escalation exercises
• Regularly assess trends in use-of-force data
• Consult a community advisory panel on policies and procedures
• Implement “bark and hold” canine deployment techniques
• Ensure meaningful access to services for limited English proficiency residents

An independent monitor was appointed to oversee compliance. The city admits no fault under the settlement but agreed to comprehensive reforms in exchange for avoiding a protracted legal battle.

7.3 Monitoring Reports and Current Status

The monitoring process has produced three annual reports to date, showing a mixed picture:

A December 2025 monitoring report analyzing personnel complaints raised alarms that a small number of officers accounted for a disproportionate share of complaints. KGET reported that “a few officers account for over a quarter of 2024 complaints.”

More positively, BPD’s Use of Force Annual Review for 2025, released April 2, 2026, recorded a significant decrease in use-of-force incidents. Officers responded to a high volume of calls while using force less often than the previous year. The department also reported 213 personnel complaints in 2025, representing a 12% increase from 2024.

As of December 2025, monitoring is ongoing. The stipulated judgment was set for five years (2021–2026), with the parties permitted to jointly petition to terminate after three years. The investigation and monitoring represent one of the most significant state-level interventions into a local police department in California history.

8. Evolution of California Law (2009 – 2026)

California has been at the forefront of police use-of-force reform over the past decade and a half. The following timeline captures the key legislative, judicial, and administrative developments:

9. Findings and Conclusions

This survey yields the following principal findings:

1. There is broad national consensus that baton strikes to the head, neck, groin, kidneys, and spine constitute deadly force and are prohibited except in life-threatening situations. This consensus spans police department manuals, federal agency policies, academic model policies, and international human rights standards.
2. Permitted target areas are primarily the arms and legs, with specific techniques (peroneal nerve strikes, femoral nerve strikes) designed to achieve temporary motor dysfunction and pain compliance with minimal risk of serious injury.
3. There is no fixed number of “appropriate” baton strikes. The standard is objective reasonableness evaluated under the totality of circumstances. However, continued strikes after a subject is controlled, or strikes far exceeding what is needed to achieve compliance, have been found to constitute excessive force in courts and public opinion.
4. Force against purely non-compliant (passive resistance) subjects is increasingly prohibited under modern policies. The Stanford Model Policy, reflecting the current consensus, explicitly bars baton strikes on compliant or passively resistant individuals.
5. Bakersfield, CA represents a significant case study in how systemic patterns of excessive force can persist despite internal review processes that routinely find all force “reasonable.” The 31 broken-bone cases between 2016–2019, with zero disciplinary findings, illustrate how internal review can fail as an accountability mechanism.
6. California has been a national leader in reforming use-of-force laws, moving from a “reasonable” to “necessary” standard (AB 392), mandating de-escalation, and expanding transparency through SB 1421.
7. Independent monitoring, body-worn cameras, and community oversight are emerging as critical accountability mechanisms. The Bakersfield stipulated judgment, with its independent monitor and community advisory panel, represents a model for state-level intervention into local police departments with patterns of excessive force.

10. Sources and References

Albany (CA) Police Department. Impact Weapons Training Manual. Albany PD

National Institute of Justice. The Use-of-Force Continuum. August 3, 2009. https://nij.ojp.gov/topics/articles/use-force-continuum

Stanford Law School, Stanford Center for Racial Justice. Model Use of Force Policy, Chapter 8: Batons. November 11, 2022. Stanford Law School PDF

Baltimore City Police Department. Policy 1111: BATONS. PowerDMS

U.S. Customs and Border Protection. Use of Force Policy. January 2021. CBP PDF

U.S. Department of Justice, COPS Office. Use of Force Policy. COPS Office PDF

San Francisco Police Department. DGO5.01: Use of Force Policy and Proper Control of a Person. SFPD

Amnesty International. Batons and Other Handheld Kinetic Impact Weapons. 2022. Amnesty PDF

Wikipedia. Peroneal strike. Wikipedia

St. Louis Metropolitan Police Department. Use of Force Policy. SLMPD

California Commission on Peace Officer Standards and Training (POST). Learning Domain 20: Use of Force/De-escalation. POST

Graham v. Connor, 490 U.S. 386 (1989). Justia

California Legislature. Assembly Bill 392 (California Act to Save Lives). 2019. CA Legislature

California Legislature. Senate Bill 1421. 2018. CA Legislature

Pickoff-White, Lisa; Ewald, Ross; Echeverria, Danielle. “Bakersfield Police Broke 31 People’s Bones in Four Years. No Officer Has Been Disciplined for It.” KQED, June 16, 2021. KQED

California Department of Justice. Attorney General Bonta Announces Stipulated Judgment with the Bakersfield Police Department. August 23, 2021. CA DOJ

California Department of Justice. Complaint: State of California v. City of Bakersfield. August 23, 2021. CA DOJ

Cahill, Nick. “Bakersfield Police to Overhaul Use-of-Force Guidelines to Settle Civil Rights Suit by California.” Courthouse News Service, August 23, 2021. Courthouse News

CNN. “Bakersfield: State Investigation Finds a California Police Department Violated Constitutional Rights.” August 23, 2021. CNN

ACLU of Southern California. Unconstitutional Patterns & Practices. August 2021. ACLU SoCal PDF

Civil Rights Litigation Clearinghouse. State of California v. City of Bakersfield. BCV-21-101928. Clearinghouse

The Guardian. “The County: Where Deputies Dole Out Rough Justice.” December 4, 2015. The Guardian

Bakersfield Police Department. Use of Force Annual Review 2025. April 2, 2026. BPD

Bakersfield Monitor Team. Third Annual Report. April 4, 2025. Bakersfield Monitor

Indiana Law Enforcement Academy. Uniform Statewide Defensive Tactics Training Program. ILEA