In 1991, Plakas drove his car off a State road into a ditch. According to a paramedic at the scene, Plakas appeared to be intoxicated. He was handcuffed but complained of pain because of scar tissue on his chest. The police officer told Plakas he was following department policy and left the handcuffs on. Plakas managed to get out of the police car and fled. When the police officer caught up with him, Plakas assaulted the police officer with a poker. The police officer shot Plakas. Plakas was pronounced dead sometime after he arrived at the hospital. The court held that the police officer had acted in self-defense, although the appellants argued that the police officer should have used less lethal alternatives. The court reiterated that the fourth amendment does not require the use of the least deadly alternative as long as the use of deadly force is reasonable. Situations in which police use of deadly force may be appropriate are noted. 14 footnotes