In State v. Clary, 196 Ariz. 610, 2 P.3rd 1255 (Ariz. App. 2000) it was held that police officers used objectively reasonable force when they held a suspect down on the floor in a police station in order for a phlebotomist to draw his blood. In these proceedings, the police were required by state statute to obtain a judicially issued search warrant to extract blood. Additionally, when addressing the Fourth Amendment claim of unreasonable search, the Court analyzed the reasonableness of the officer's conduct under Graham v. Connor.