Determining whether a police officer should receive qualified immunity from a constitutional claim requires the court to determine first whether the officer’s conduct violated clearly established law and whether that conduct was objectively reasonable. However, the findings of studies vary regarding whether hog-tying results in positional asphyxia. Studies conducted in the 1980’s concluded that maximal restraints after a violent struggle could impair the mechanical process of inhaling and exhaling and could result in sudden death. Cases examining these issues consistently involved detainees placed in a prone position; the method of restraint varied from case to case. However, more recent research has suggested that maximal restraints under these circumstances may be physiologically neutral and questions the underlying research involved in the initial studies. The 1998 judicial decision in Price v. County of San Diego, et al, supported the latter view. Another court in a similar 1998 case, Gutierrez v. City of San Antonio, cited data suggesting that many large police agencies had banned hog-tying and considered both this finding and Reay’s research conclusion that the restraint was physiologically neutral. However, the research and testimony described in the Price opinion indicate that it is far from "clearly established" that the restraint position causes asphyxia.