A carotid restraint hold is a method of cutting off blood flow to the brain and rendering the subject unconscious, ideally in a matter of seconds. The hold is achieved by placing an arm around the subject’s neck from behind, with the front of the neck which houses the trachea squarely and safely in the crook of the elbow, while using the upper arm and forearm to apply pressure to the carotid arteries in the sides of the neck.  

Police agencies in some jurisdictions have continued to defend using the carotid restraint hold for decades, claiming that it is safer and more effective than using a police baton, taser, or pepper spray. Other jurisdictions have banned its use entirely while still other jurisdictions have ruled that it may only be used in extreme situations where deadly force is justified.  Unfortunately, because cops in some departments are still allowed to resort to this method of controlling unruly suspects and detainees, people continue to suffer grave injury and death from use of the carotid restraint hold. Learn more about Police Misconduct.

restraint hold

Restraint holds–what are police allowed to do?


What is the Difference Between a Carotid Restraint Hold and a Arm-Bar Chokehold?

What they have in common is applying pressure to the neck with an arm, effectively “choking” vital passageways to cause the subject to lose consciousness.  An Arm-Bar chokehold is where you place the forearm across the front of the neck, compressing the trachea (windpipe) to cut off oxygen and stop breathing. There’s a serious danger of crushing the trachea when applying this hold as it can cause damages to the organs of the neck. Also, if breathing is cut off for too long it can cause serious brain damage or death. 

With a carotid restraint, or “sleeper” chokehold, you compress the arteries at the sides of the neck, cutting off blood flow to the brain so the subject loses consciousness but not obstructing the airway so the subject cannot breathe. However, the carotid restraint can easily turn into an arm bar during a struggle. Usually if a subject dies after being choked with the “carotid restraint hold” the cause of death is listed as asphyxiation.

Imagine a scenario where a cop is trying to subdue a subject who is panicked and struggling against restraint. The officer manages to get behind the subject and place an arm around that person’s neck. In all probability this will cause the subject to react by struggling harder, yet despite the subject’s movements the officer is in theory able to apply the carotid restraint, rendering the panicked subject unconscious in less than a few seconds. Because of the dangers associated with the carotid restraint, this use of force must be objectively reasonable in light of the circumstances the officers the officer is facing. Some police agencies deem this technique as deadly force for obvious reasons and can only utilize when the officer is facing an imminent threat of serious bodily injury and/or death.


The Carotid Restraint Hold Can Turn Deadly if the person is struggling to breathe

There have been numerous incidents in recent years where subjects have died from being choked out during an arrest. 

In practice, use of any restraint which relies on placing an arm around the neck of a panicked subject, especially one who is struggling to breathe, when pressing down can quickly turn deadly. There is a narrow margin of error even when correctly applying the carotid restraint to avoid serious injury and death. 

A big problem is that when a subject is panicked and thrashing around one twist of the body can change a carotid restraint into a deadly chokehold. In every deadly incident the officer involved claimed to have used a carotid restraint hold, not a chokehold to subdue the subject.


Some Police Haven’t Been Properly Trained in Use of the Carotid Restraint Hold

During testimony in the recent wrongful death case, Fermin Vincent Valenzuela v. City of Anaheim et al, both Woojin Jun and Daniel Wolfe, the arresting officers involved in Valenzuela’s wrongful death admitted lack of training in using the carotid restraint. Their supervisor Daniel Gonzalez testified that he didn’t remember whether his training included how to determine if the carotid restraint was applied correctly. Along with the carotid restraint, Jun and Wolfe tased Valenzuela and struck him repeatedly with a baton. 

In the circumstances which led to Valenzuela’s death, Police were called after a woman claimed Valenzuela, who was homeless, had been following her and was pacing up and down in front of her apartment building.  Police body cam footage shows that Valenzuela was in a laundromat loading clothes from his backpack into a machine when Jun and Wolfe arrived at the scene and confronted him. 

Although Valenzuela broke free and ran after being choked and tased repeatedly while he was on the laundromat floor, at no point did Valenzuela draw a weapon or give police a reason to fear he posed an imminent danger to anybody.

Anaheim officers’ lack of expertise in using the dangerous carotid restraint resulted in a broken hyoid bone and caused Valenzuela’s wrongful death, due to complications resulting from asphyxiation. 

Despite all this, Anaheim spokesman Mike Lyster insists that the federal district court’s ruling and the $13.2 million awarded to Valenzuela’s children is a miscarriage of justice. Lyster stated that the responding officers had only two options, to “engage” or to walk away. Apparently de-escalation is not in Lyster’s frame of reference.

asphyxiation by police


People Can Die from the Carotid Restraint, Even When It Is Correctly Applied

In January 2019 two Fort Wayne, during their training Indiana police officers suffered serious injury while a carotid restraint holds (also called lateral vascular neck restraint) was applied on them. If carotid restraint training can be so dangerous, obviously real-life encounters with panicked subjects is even more dangerous.

A 1993 L.A. Times article titled Final Suit Over LAPD’s Use of Chokehold Settled states that use of the carotid chokehold led to 16 deaths in seven years. Because of those deaths and the subsequent lawsuits, the Police Commission banned chokeholds except in situations where deadly force is required. However, police continued to argue that the carotid restraint hold should be reinstated because it is safer than tasing or baton use. 

Carotid restraint cases come to the attention of the public on a regular basis due to serious injury or death. In these cases we invariably find that police used the carotid restraint hold along with other methods in their arsenal such as tasing and beating a subject with batons.

Arguments for and against use of the carotid restraint hold have continued for decades in various jurisdiction nationwide, while people continue to suffer serious injury and death.


How Many Deaths Will the Carotid Restraint Chokehold Cause Before is Deemed Too Risky to Allow Anywhere?

The one time a chokehold case made it to the United States Supreme Court was the 1983 case, Los Angeles v. Lyons. This case was brought by Adolph Lyons, a young African American man who was choked out by an LAPD officer during a routine traffic stop. 

Lyons complained about rough treatment after being stopped for a burned-out taillight. The next thing he knew one of the two officers who stopped him and ordered him out of the car at gunpoint applied a bar-arm hold to his neck, continuing to choke him while cuffing him until he lost consciousness. He woke up face down on the ground, gasping for air, with a mouthful of dirt and having soiled himself. 

Lyons sued for damages and injunctive relief, requesting that the federal court ban use of chokeholds in all but situations where a suspect poses a threat of imminent harm to others. The Supreme Court ruled against Lyons 5 to 4, stating that Lyons couldn’t predict whether he’d be placed in a chokehold again, therefore had no stake in whether chokeholds continue to be allowed. Justice Thurgood Marshall called this reasoning absurd in his written dissent. 

In the decades since the Supreme Court sidestepped the issue of whether police should be allowed to use chokeholds on subjects who pose no imminent threat, people have continued to die from the application of this brutal technique. In the overwhelming majority of these deaths, the victims were unarmed and simply resisting arrest or panicked.

Orange County attorney for prison abuse


Call the Sehat Law Firm if You or Someone You Love is Injured or Killed By the Police

No matter what people such as Anaheim spokesperson Mike Lyons say, they do not respect the sanctity of life inherent in each human being. What they do respect is money—the last thing these people want is to continue to pay out enormous sums of money after being sued by victims of police brutality or their surviving family members. This is the real tragedy—that people in power have so little regard for the Constitutional rights of ordinary people they have been entrusted to protect and serve.

Read Ongoing Psychological Support for Police to Reduce the Cost of Police Misconduct.

If you or somebody you love is a victim of police brutality, contact attorney Cameron Sehat without delay, Sehat Law Firm are here to help you. By filing a federal lawsuit you will be joining the battle to keep our communities safe from police who wield unfettered power against members of the public. Together we can stop the killings and demand accountability.

The Sehat Law Firm, PLC is here for you. Call us today for a free consultation.