The parties call our attention to two published cases applying
Graham to instances of police use of dogs, and we agree these cases bear heavily on our analysis in this case. First, in
Crenshaw, we held that it was objectively reasonable for an officer to briefly use the force exerted by a police dog to subdue and detain an armed suspect until he could be handcuffed.
556 F.3d at 1291–93. The suspect in that case, Crenshaw, was thought to have committed at least one, and possibly two, armed robberies, on the same night that he was spotted by police.
Id. at 1291. Upon being pursued by the police, at night, Crenshaw actively fled—first in his vehicle and then, after crashing his vehicle into a marked patrol car, by foot.
Id. He entered a densely wooded area, laid on the ground, and shouted out his location in an attempt to surrender.
Id. After doing so, the dog located Crenshaw and bit him thirty one times.
Id. Within three to five seconds after releasing the dog, the officers surrounded Crenshaw and ordered him to give up his hands.
Id. at 1286. Because Crenshaw “did not immediately give up his hands,” the officer grabbed Crenshaw's right hand.
Id. at 1286–87. The officer then handcuffed Crenshaw's left arm and called off the dog.
Id.