J.R. is a special education student with an emotional disability. During an incident in which he was misbehaving, the school called the resource officer to restrain him. After he was placed in handcuffs in a seclusion room and while he was on the floor, the resource officer pepper sprayed him. We filed a § 1983 excessive force police misconduct case seeking an injunction to improve the pepper spray policy in this school district, which allowed too much discretion in school resource officers.