The claim must focus on whether the use of force by the officers deprived the plaintiff of a Federal right while the defendant was acting "under color of State law." Based on previous court decisions, the standard for a law enforcement officer's use of force is its reasonableness. This involves such factors as the need for the application of force, the relationship between the need and the amount of force that was used, the extent of the injury inflicted, and whether force was applied in a good faith effort to maintain or restore discipline or maliciously and sadistically for the purpose of causing harm. Expert testimony can analyze whether the officer or officers in the case acted reasonably under professional standards. The defense will raise two principal issues on summary judgement: qualified immunity for the individual officers and the absence of a policy or custom that is needed to impose municipal liability. The plaintiff can overcome the immunity defense by showing disputed issues of material fact. Establishing the link between policy and performance can overcome any argument that the municipality is not liable for individual officer behavior. Guidance for trial proceedings focuses on plaintiff's dress, being "up-front" about the plaintiff's background, plaintiff's behavior in the courtroom, sticking to the plaintiff's initial reporting of events, and avoiding inflated claims of psychological distress. 20 notes