In February 2012, Officer Choate was involved in an incident where inmate Dwain Smith, who was experiencing severe pain, was tased twice by fellow officer Jacob Zulpo. Choate did not intervene during the tasing, leading to allegations of failure to prevent the use of excessive force. The court denied qualified immunity to Choate, allowing the claim to proceed. [Source: Smith v. Conway County, Arkansas, et al., No. 13-3095 (8th Cir. 2014)]
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