While the force continuum remains constant for controlling and arresting all persons, a number of cases suggest that agencies must conduct training for dealing with the emotionally disturbed and mentally-ill persons in the context of use of force. Many agencies have policies related to civil commitments and dealing with the mentally ill, yet few agencies actually conduct training related to these policies and even fewer train on tactics and use of force in the context of the emotionally disturbed and the mentally ill. In Gaddis v. Redford Township, and City of Dearborn Heights, 364 F.3d 763 (6th Cir. 2004), the [...]