A collateral trend in police-directed litigation claims officers often inflict emotional distress. Arresting a person, handcuffing suspects, or pointing a firearm at individuals are seen as fear-inducing events. Courts are beginning to recognize claims against police officers who knowingly display or threaten force which would create substantial fear in the average citizen, if the force threatened or displayed is not justified by the circumstances. A "mere handcuff" rule conflicts with the fourth amendment's objective reasonableness standard for the use of force. Determining whether the force used to effect a particular seizure is objectively reasonable is assessed after considering the facts and circumstances confronting the officer without regard to the officer's underlying intent or motivation. Police officers are trained and required to employ reasonable apprehension techniques and exhaust every reasonable means of apprehension before resorting to the use of force of any kind. The officer's use of justified force must be based on an imminent necessity to counter an imminent threat, given the officer's perception of the arrestee's capability, opportunity, and intent to harm the officer or others. An officer is not justified in using physical force to overcome a future or past threat of harm. Rules governing the use of handcuffs must be tempered by the officer's judgment and discretion. Police department policies must not predetermine the use of handcuff force, since mere handcuffing contradicts the standard of objective reasonableness.