Domestic Enemy to the Constitution of the United States unlawfully uses pepper spray for passive resistance, which is excessive force and a violation of the 4th amendment.
>Using pepper spray for passive resistance is generally considered excessive force and is often prohibited, as it is reserved for active, violent threats. Courts have found that using pepper spray on passively resisting individuals is an excessive use of force. The reasoning is it is a form of torture that can not be "turned off" once compliance is achieved. It's use is only for active violent threat.