Read the following excerpt from a US court opinion:
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against an unreasonably excessive use of deadly force in the form of Quando, a police canine. Even excluding the question of whether the police dog constituted deadly force, a jury well could find that, given the circumstances, the totality of force used— four blasts of pepper spray, slamming Smith down onto the porch, dragging him off the porch face down, ordering the ca nine to attack him three times, and the resultant dog bites and physical assaults on his body — was unreasonable. We have indeed held on past occasions that the use of lesser force could be unreasonable in the particular circumstances. See Santos, 287 F.3d at 853-54 (shoving can amount to excessive force when it is unreasonable); Headwaters Forest Defense v. County of Humboldt, 276 F.3d 1125, 1130-31 (9th Cir.2002) ; Watkins v. City of Oakland, 145 F.3d 1087,
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What is the most suitable continuation to the opinion? Your options are:
A. holding that forcibly removing nonviolent plaintiff from her car could be excessive force
B. holding that two bursts of pepper spray to stop fighting in a cell was not considered excessive force and did not violate prisoners eighth amendment rights
C. holding that the use of pepper spray on nonviolent protestors was excessive force
D. holding that otherwise acceptable use of pepper spray became excessive when arrestee was offering no further active resistance
E. holding that bystander prisoners who were exposed to pepper spray when prison officials dispensed spray across their pod area to break up a fight were not subjected to excessive force
Reply with [A, B, C, D, E] only.