State v. Lewis
In State v. Lewis, 115 Ariz. 530, 532-33, 566 P.2d 678, 680-81 (1977), while one officer applied a choke hold to prevent a suspect from swallowing a balloon of heroin, another slapped her on the back.
After struggling for several minutes, the police forced the suspect to cough up the evidence. Id. at 532, 566 P.2d at 680.
The court found that the amount of force was no more than "reasonably necessary" and did not "shock the conscience." Id. at 533, 566 P.2d at 681.