Both California and Federal law permit police officers to use objectively reasonable force in making an arrest and to prevent escape. Many judicial decisions have held that the use of police dogs is an objectively reasonable use of force when used against burglars and other felony suspects who hide inside buildings or around inhabited areas following the commission of their crime. Although one judge in the 1994 case of Chew v. Gates held that the use of dogs was deadly force, the other judges in the case disagreed. All the Chew decision did was remand the case to trial court for trial on the issue of whether Los Angeles has an unconstitutional canine policy. Instead of focusing on the Chew decision, police agencies should focus on the Mendoza and Rivera decisions regarding how to use police dogs properly to locate and apprehend felony suspects. Citizens will always appreciate a properly trained and supervised canine unit, because it is clear that the use of dogs reduces the likelihood of having to resort to deadly force and saves lives, including the lives of suspects.