Inside the Lines

Limits on the Use of Force

An article based on the Safety Member Certification training module "Basic Use of Force Laws," the Church Security Guide article "Self Defense Laws, Your Rights and Use of Force," and the Expert Resources articles "Less-Lethal Skills for Church Safety Teams: A Guide for Prepared Protectors", "Even If You're Right—You Can Still Be Sued," and "Does Church Insurance Actually Cover You?" [1][2][3][4][5].

In the Bible

And when there arose a great dissension, the chief captain, fearing lest Paul should have been pulled in pieces of them, commanded the soldiers to go down, and to take him by force from among them, and to bring him into the castle (Acts 23:10).

Introduction -

The correct "use-of-force" has become a hot issue in our society. Sixty years ago complaints that police used "excessive force" were in the news. Governments, federal to local, have been wrestling with this issue ever since. Riots have also erupted over alleged excessive force incidents, such as Rodney King, Michael Brown, and George Floyd.

Use-of-force is also an issue for businesses and places of worship. A key consideration is being welcoming and secure at the same time. As with law enforcement, there are legal challenges, too.

On the Web -

More lawsuits about use-of-force:

Charlotte North Carolina, July 5 2021 - In a July 2021 Private Officer Magazine article, "Lawsuits Against Private Security Continue Rising," the author noted the increase of lawsuits against not only law enforcement agencies and officers, but especially against private security providers. Although not specifically mentioned, this is also true for church safety & security teams, their members, and the churches. There were over 100 million criminal trials and about 400 million lawsuits related to use-of-force in 2020. With a population of 340 million, that is a very weighty number.

Part of this comes from how easy it is for someone to file a lawsuit. Often one person will file several lawsuits. For a church safety ministry, this could be one lawsuit against the church, one against the safety ministry, and one each against individuals.

Add to this the number of law firms advertising their services for personal injury lawsuits or advising how to file a lawsuit. In this case, the power of suggestion is a multiplier of lawsuits [6].

Unarmed use-of-force can result in criminal charges:

Post Falls, Idaho, November 7, 2024 - Church security team members tried to stop a skateboarder coming in off the street from getting into a High-School Ministry Night meeting with many youth present. The skateboarder (a 20-year-old man) ignored verbal commands and gestures. When one security officer, a retired and decorated Marine, held out his hand, the intruder ran into it and lost his balance, falling off the skateboard. The young man left in a fit of anger.

The church did not ask for the intruder to be charged with trespassing, but the intruder asked for assault-and-battery charges, so it was the volunteer who was criminally charged, not the intruder. According to a news source, the intruder claimed he could not hear the security members' because he was wearing headphones listening to music [7][8].

Coeur d'Alene, Idaho, February 22, 2025 - Actions of private security guards during a town hall have resulted in the county prosecutor filing criminal charges of battery and false imprisonment. A woman who shouted during the meeting was asked to leave, and refused. The security personnel physically dragged her out. Ironically, this was at the request of the county sheriff [9].

San Diego, California, July and October, 2019 - The Bureau of Security and Investigative Services in California began looking more closely at private security services contracted by government agencies after actions of security guards on San Diego's Metropolitan Transit System resulted in two deaths in July and October of 2019. In May 2021, the private security company was sued in federal court by the family of one of the victims [10].

A lack of discretion triggers outrage:

Seattle, Washington, March 27, 2024 - A combination of outrage and concern in Seattle was raised by a posted video of a security guard at a pharmacy who was heavily armed and armored. The same guard allegedly acted aggressively. His actions included his detaining the person shooting the video as a suspected shoplifter. It turned out that the person was not a thief, but had paid for what she had. Investigation showed that the guard's security license had been suspended, meaning he was not licensed at the time of the encounter [11].

Counter claims about stun gun use:

Hartford, Connecticut, November 16, 2022 - There are two sides to everything, as in the case of a woman arrested in a hospital in Hartford. The woman is suing the hospital for their security throwing her to the floor and for false arrest. At the same time, the city police, who arrested her, claim she pulled a stun gun during the incident [12].

Lethal force is justified by defense of another:

Nevada County, California, February 4, 2021 - Two sheriff's deputies responded to several calls regarding a woman with two children walking along a road in cold weather while acting in an erratic manner. When the deputies found the woman, they tried to calm her. Instead, she presented a knife menacingly. The deputies tried to keep their distance while talking to her, but she moved toward one deputy who warned her and drew his gun. The other deputy had a Taser, and ordered her to stop. When she did not stop, he tazed her, but it had no effect. Instead she lunged at him with the knife. The other deputy shot her with his firearm, killing her.

The woman's family sued the county on behalf of the children, charging the deputies with emotional harm. The local court sided with the family, but the county appealed. The state appeals court sided with the county. Since the Taser failed and the woman was attacking that deputy with a knife, the other was justified in defending his partner. The presence of children did not negate the duty to defend a life.

Keith Graves of Christian Warrior posted an analysis of this incident and how it applies to church security ministries. He included a training pattern for learning to deal with mentally-disturbed disrupters threatening violence [13].

Where's the Line?

The standard for defining levels of force is the Continuum of Force, which begins with the presence of authority, whatever kind it is, and progresses to lethal force. According to the National Institute of Justice, the levels of force are -

1. Officer Presence,
2. Verbalization,
3. Empty-Hand Control,
4. Less-Lethal Methods,
5. Lethal Force [14].

Any level above presence may be called into question by someone who considers it too much. Yes, even making commands or suggesting a change of behavior can be construed by some as unwarranted force. It seems that any pretext for a complaint, an injury claim, or a lawsuit will do. However, statutory law and court decisions generally weed out frivolous claims, but usually only after defendants have spent time and money on their defenses.

In church security, we need to know how to stay within the legal lines while still keeping people in the church safe and secure. First, know the Continuum of Force, then learn when certain actions within each level are acceptable, borderline, or unacceptable, especially in state and local laws.

The Continuum of Force -

Here is a brief overview of the Continuum of Force minefield:

Level 1: Officer Presence:

Legally, this is the safest level of force. The visibility of law enforcement or security can be a comfort to many and a deterrent to thieves and other bad actors. Just watch how traffic keeps to the speed limit when a police cruiser is visible. There is hardly any liability to just being there, even though some today may consider that to be excessive.

Level 2: Verbalization:

Potential liability is not limited to physical force. For instance, the second level of the continuum is verbalization, which is non-physical:

- Officers issue calm, nonthreatening commands, such as "Let me see your identification and registration."

- Officers may increase their volume and shorten commands in an attempt to gain compliance. Short commands might include "Stop," or "Don't move" [1].

Demanding that a person stay in one place can be considered an arrest or a detainment. Even if it's not a demand, but simply asking the person to stay, it may be construed by some as a detainment or arrest. If the request is carefully worded, and the encounter is witnessed and recorded, you may have evidence that it is not coercive. Kris's latest Expert Resources article, "Even If You're Right—You Can Still Be Sued," shows the need for documentation to prove that you were in the right [4].

An actual citizen's arrest is problematic since it has to meet specific criteria to be legal.

Level 3: Empty-Hand Control:

Being overly physical while unarmed can bring about a charge of excessive use of force, especially if it results in an injury.

In Post Falls, ID, it is immediately apparent from witnesses' testimony that the skateboarder fell because he was not paying attention. This did not deter him from requesting criminal charges against the security person for assault and battery [6].

Unarmed conflict can ignite criminal charges and lawsuits, especially if there is an injury. It pays to be properly trained in unarmed self-defense and to know when more forceful moves are needed. It's safe to say that unarmed control-and-defense has a continuum all its own.

Level 4: Less-Lethal Methods:

In Nevada County, CA, the use of less-lethal force (a Taser) failed, but it was tried in an attempt to avoid lethal force [12]. In the Hartford hospital incident, the person who caused the disruption pulled out a stun gun. According to basic use-of-force rules, this was unjustified, so she was arrested. Self-defense applies only when the "defender" was not the instigator [11].

The most popular less lethal weapons are defensive sprays with OC (pepper oil), CS (tear gas), or a combination of the two. The possession and use of these sprays faces a variety of local and state regulations. Therefore, it pays to familiarize yourself with applicable laws.

As with defensive sprays, electric discharge devices (especially Tasers) have a patchwork of state regulations. In all states plus the District of Columbia and Puerto Rico, it is legal to own and possess a Taser. Thirteen states and D.C. have no further regulations at this time. The other 37 states and Puerto Rico have regulations, the most common being a minimum age for having a Taser.

Other less-lethal weapons include batons. In some jurisdictions they are restricted to law enforcement officers while in some other locations they may be used by those trained in their use. The reason for regulation is that they are capable of inflicting serious body damage with the potential of being lethal.

Level 5: Lethal Force:

Lethal weapons include more than firearms, edged weapons, spears or arrows, and explosives. They can include baseball bats, shovels, rocks or bricks, a rope (which was used by the assailant in Fort Dodge, IA), and vehicles [15].

The use of lethal force is not based on the weapon itself, but on the circumstances of its use. Because they are more lethal (and are designed to be so), firearms face more regulations. Nevertheless, we should consider the potential lethality of whatever is in our hands and whether it is needed and justified in the situation.

Staying in the Lines -

An old saying is, "Good fences make good neighbors." Why is this so? It is because a fence makes the property line visible. By learning the laws, regulations, and significant court decisions for use-of-force (the legal fences), we see where the lines are. This should inform our training and drills so that we can make the right decisions in an incident.

The basic actions for conditioning ourselves to use force discretely are -

• Learning verbal de-escalation,
• Learning the limitations for citizen's arrest,
• Training in unarmed defense and control,
• Having and learning how to use less-lethal weapons,
• Learning when to use or not use lethal force,
• If armed, gaining proficiency.

Learn Verbal De-escalation:

Verbal de-escalation is the key second-level skill in the use of force. Its primary goal is to cool down a heated situation so it does not become worse. A proactive goal is to keep a situation peaceful. In Colossians 4:6 Paul wrote, "Let your speech be always with grace, seasoned with salt, that ye may know how ye ought to answer every man." He was drawing on Proverbs 15:1 - "A soft answer turneth away wrath: but grievous words stir up anger."

Learn Citizen's Arrest Limitations:

Citizen's arrest has been glamourized in entertainment media, especially movies and TV shows, and activists of various causes have threatened to use it on public figures. However, it is not always that convenient, and it carries the risk of the arrestor being charged with or sued for false arrest (or imprisonment), sometimes called "kidnapping." There are legal guidelines as to when a citizen's arrest is used. Basically they are:

1. When the public offense is committed in the presence of the arresting person.
2. When the suspect has committed a felony (not necessarily in the arresting person's presence) - an example of this is recognizing and arresting a known and wanted criminal (such as one whose photo is on the FBI's most-wanted board in the Post Office).
3. When, in fact, a felony has been committed, and the arrestor has reasonable cause to believe that it was committed by the suspect.

Recently, Georgia tightened the rules for a citizen's arrest to be in line with the above criteria.

Train for Unarmed Defense and Control:

Self-defense classes teach skills derived from martial arts (such as Judo, Karate, Krav Maga, etc.) and sports (such as wrestling and football). Besides defense, certain moves and holds can be used to control an uncooperative person.

Two caveats for these skills are

1. Do not use them unnecessarily, and
2. Avoid excessive force.

It is recommended that church safety team members have in-person training in unarmed self-defense and control, then practice it regularly to keep muscle memory fresh.

Using Less-Lethal Weapons:

Security experts advise persons carrying lethal weapons to also have less-lethal devices. That way the person has a less-lethal option when lethal force is not really necessary. The choice of a less-lethal device and how to use it may be covered by state or local laws, so it pays to know the laws in your jurisdiction.

Defensive Sprays,

Some states regulate OC (pepper) sprays and/or CS (tear gas) sprays. Pepper spray has the potential of causing eye injury and/or breathing problems. Permits or special training may be required, depending on where you are. These sprays are generally effective in stopping an assailant. Using a defensive spray offensively (not in defense) may be legally considered assault and battery. This means it's inadvisable to spray someone just because you don't like what they said or how they look.

Electric Discharge Devices,

Stun guns and Tasers may also be regulated in some jurisdictions. How they differ is that the stun gun requires direct physical contact, while the Taser fires a pair of electrodes to penetrate clothing and deliver the shock. As seen in the Nevada County case, the Taser does not always work. Considering the cold weather at that time, the suspect's clothing may have been too thick for both electrodes to make contact.

One caution for a Taser is to avoid eye injury by not firing at the face.

Bola-Wrap,

The Bola-Wrap is an adaptation of the bola, a South American version of the lasso. It discharges two weights at the ends of a line. When the line hits a suspect, the weights swing around, binding him with the line. The advantage is the avoidance of serious injury to the suspect. As of now, it is, for some reason, still distributed only to law enforcement agencies.

Learn When to Use or Not Use Lethal Force:

The question of when to use lethal force is answered differently by separate states. Generally these laws fall into four categories:

• Common Law,
• Castle Doctrine,
• Stand Your Ground,
• Duty to Retreat.

In different states, statutes and court decisions color these categories differently. For instance, how the duty to retreat is applied and areas covered by the castle doctrine. In some locations, the duty to retreat applies within your home, but in most others it does not. In some states, the castle doctrine applies to your vehicle. A stand-your-ground defense may be challenged in some situations.

Currently, law enforcement officers are expected to have less-lethal devices. In a questionable situation, a law enforcement officer not having a less-lethal weapon could be considered negligent by some judge or jury if its use may have made lethal force unnecessary. In today's legal and judicial climate, if this hasn't been applied to non-professional security personnel in your jurisdiction, don't assume it won't be.

Gain Proficiency in Lethal Weapons:

You don't want just anyone carrying a lethal weapon. You'd expect a gun holder to know how to use it. For instance, people pulling handguns out of holsters have accidentally shot themselves in the foot. You want the gun holder to know how to use the safety, how to aim, when to shoot or not shoot, etc. Proficiency in firearms is for the safety of both the holder and others, and in a dangerous situation it could mean an effective defense.

The Right Weapon,

Choose the weapon that is right for you. It has to have enough firepower, yet be light enough to use. If it is a concealed carry weapon, you should be able to conceal it, yet be able to draw it quickly enough when needed. Along this line, choose the right holster for you. Some experts prefer the .38 cal. short or 9mm short as a balance of power, concealment, and ease of drawing. Others have different choices.

Care of the Weapon,

Active shooters whose guns jam teach us a lesson: maintain your weapon for reliability and safety.

• Handle your firearm with respect. A dinged-up gun is a safety hazard for the user. If the bullet cannot exit properly, the weapon may explode. On the other hand, it may not work at all when needed.
• Clean the firearm regularly. Don't let residue build up. A clogged barrel is a safety hazard. Keep the moving parts clean and lubricated.
• Get the right ammo. It has to be the same caliber as the gun, and the shell has to be the right length. It has to fit.

Training,

Get training in how to use your weapon. Refine your aim on the firing range. By the way, wear ear protection.

Also include tactical shooting. An active killer is not concentric circles on a piece of paper. You need to shoot a moving target which may be partially concealed. You need to know how to keep the gun trained on the killer when there's a crowd and wait for the right moment to shoot. You need to be able to shoot from different positions, as well as under, over, or around your cover.

Practice,

The firing range is there not only for learning how to shoot, but for practice. Use the range regularly to keep your skills sharp. Keep a record of your practice sessions.

Team Drills,

In team drills, members practice their roles in a response to deadly force. Drills can be held in the church so armed team members practice knowing how to respond in that location:

• When and how to draw weapons,
• How to position in relation to the intruder,
• How to move from cover to cover, and
• How to shoot from cover.

Drills will vary as to

• How, when, and where the incident begins,
• The number of intruders,
• The type(s) of weapons used, etc.

Use-of-Force Hazards -

Using force in defending the flock has its hazards. Inherent hazards are:

• An already violent disruptor,
• Weapons used by a disruptor or intruder,
• Injuries from defense-and-control moves,
• Obstacles and tripping hazards in the area,
• Shots fired by a teammate ("friendly fire").

There are also social and legal hazards.

One social hazard is in community relations. For instance, an injured intruder, even in an unarmed incident, such as the one in Post Falls, can try to make himself or herself appear to be the victim. This is even more so with the use of lethal force. If an armed intruder is killed, the family can try to place the blame on the safety team member. In today's social-political climate, street demonstrations and picketing are possibilities.

Legal hazards are more likely. Anyone in the safety ministry, the church itself, and even the denomination or a denominational district, can be sued, and team members can be criminally charged. As happened with Jack Wilson in White Settlement, Texas, someone can be dragged through the legal process for months before a grand jury decides to not indict [16].

Kris has covered this subject in two Expert Resources articles. In "Even If You're Right—You Can Still Be Sued," he says, "The moment you physically intervene—even just laying hands on someone to stop violence—you enter the legal system. And that system is unforgiving."[4.]

Being sued can be very costly, as frequent headlines reveal massive awards and settlements. However, even if a lawsuit against you fails, there are still the legal costs. There are also legal costs in defending against criminal charges, whether or not you are convicted.

Most churches have general liability coverage, but will you be personally covered after a use-of-force incident? The kindest answer is, "Not necessarily."

Kris addressed this concern in "Does Church Insurance Actually Cover You?" First of all, it is the church and board members which are covered. This may or may not include pastoral staff and maybe some fulltime employees. Unless actually named in the policy, volunteers are left out. Why? The extra coverage raises the premiums. Even then, this may exclude criminal charges, firearms, or off-campus events.

It is in your best interest to have personal liability insurance which includes use-of-force. Read the article for Kris's advice. He does recommend Right to Bear - Legal Defense for Responsible Gun Owners.

Training Notes -

Members of church safety teams ought to be trained and certified in church security The Safety Member Certification training course has eight training modules (classes). All of these are taught online, so a person taking the classes can do it any time of day, any day of the week. Passing all eight classes will qualify one to be a Certified Safety Member for two years.

Recertification after two years not only refreshes previous training; it also updates it. Kris is updating the courses, including "Justified-A Brand-New Use of Force Course for Church Safety Teams." The training module "Use of Force for Church Safety Teams" will launch in September. Totally re-built, it includes legal training with a nationally-recognized instructor.

Other training resources include the Church Security Guide and Expert Resources. Directly relating to this article is "Less-Lethal Skills for Church Safety Teams: A Guide for Prepared Protectors." [3.]

Conclusion -

Use discretion when you use force at any level on the Continuum of Force.

References -

1. Kris Moloney, "Basic Use of Force Laws." Safety Member Certification, Sheepdog Church Security, © 2020 [https://sheepdog-church-security.thinkific.com/bundles/safety-member-certification].
2. Kris Moloney, "Self Defense Laws, Your Rights and Use of Force," Church Security Guide, Sheepdog Church Security, © 2018 [https://sheepdogchurchsecurity.net/use-of-force-arrest-laws], and re-posted 2023 [https://sheepdog-church-security.thinkific.com/pages/security-articles?p=self-defense-laws-your-rights-and-use-of-force].
3. Kris P. Moloney, "Less-Lethal Skills for Church Safety Teams: A Guide for Prepared Protectors." Expert Resources, Sheepdog Church Security, April 1, 2023 [https://sheepdog-church-security.thinkific.com/pages/security-articles?p=non-lethal-skills-for-church-safety-teams-a-guide-for-prepared-protectors].
4. Kris P. Moloney, "Even If You're Right—You Can Still Be Sued," Expert Resources, Sheepdog Church Security, July 20, 2025 [https://sheepdog-church-security.thinkific.com/pages/security-articles?p=even-if-youre-rightyou-can-still-be-sued].
5. Kris P. Moloney, "Does Church Insurance Actually Cover You?," Expert Resources, Sheepdog Church Security, July 27, 2025 [https://sheepdog-church-security.thinkific.com/pages/security-articles?p=does-church-insurance-actually-cover-you].
6. Anon, "Lawsuits Against Private Security Continue Rising," Private Officer Magazine, July 9, 2021 [https://privateofficernews.org/lawsuits-against-private-security-continue-rising/].
7. Chloe Cochran, "Church security volunteer charged with battery," Hagadone News Network (Sandpoint, ID), June 21, 2025 [https://hagadonenewsnetwork.com/news/2025/jun/22/church-security-volunteer-charged-with-battery/].
8. Keith Graves, "Decorated Marine Charged with Crime for Defending His Church," Christian Warrior, February 21, 2025 [https://www.christianwarriortraining.com/p/decorated-marine-charged-with-crime].
9. Kaye Thornbrugh, "Private security guards charged in Coeur d'Alene town hall dragging," Couer d'Alene / Post Falls Press, April 19, 2025 [https://cdapress.com/news/2025/apr/19/private-security-guards-charged-in-coeur-dalene-town-hall-dragging/].
10. Greg Moran, "Two deaths, just months apart: private security guards hired by public agencies face more scrutiny," The San Diego Union-Tribune, Updated: May 16, 2021 [https://www.sandiegouniontribune.com/2021/05/16/two-deaths-just-months-apart-private-security-guards-hired-by-public-agencies-face-more-scrutiny/].
11. Lauren Donovan, "Viral video of 'heavily' armed Seattle Walgreens security guard sparks outrage," Fox13 Seattle, April 2, 2024 [https://www.fox13seattle.com/news/armed-security-guard-walgreens].
12. Alex Wood, "Woman accused of pulling stun gun sues Hartford Hospital claiming false arrest, abuse," CT Insider, January 1, 2025 [https://www.ctinsider.com/news/article/hartford-hospital-assault-stefanie-rodriguez-diaz-20009003.php].
13. Keith Graves, "Use of Force and the Mentally Disturbed: Lessons from a California Shooting Case," Christian Warrior, July 17, 2025 [https://www.christianwarriortraining.com/p/use-of-force-and-the-mentally-disturbed?utm_source=post-email-title&publication_id=1482871&post_id=168523891&utm_campaign=email-post-title&isFreemail=true&r=3g09m0&triedRedirect=true&utm_medium=email].
14. WGV, "Colors of Force," Sheepdog Church Security, October 18, 2021 [https://sheepdogchurchsecurity.net/articles/colors-of-force/].
15. Rachel M. Moloney, "Fort Dodge Church Murder | Lessons Learned," Sheepdog Articles, Sheepdog Church Security, July 17, 2025 [https://sheepdog-church-security.thinkific.com/pages/security-articles?p=lessons-learned-from-the-fort-dodge-church-murder].
16. Matthew S. Schwartz, "Grand Jury Declines To Indict Church Security Guard Who Killed Gunman In Texas," NPR, September 29, 2020 [https://www.npr.org/2020/09/29/918185532/grand-jury-declines-to-indict-church-security-guard-who-killed-gunman-in-texas].