With no explanation, chose the best option from "A", "B", "C" or "D". Use and Abuse of Lasers and the Need for Reform (2011) 56 Vill. L.Rev. 363, 384-385 [pointing out that the Federal Law Enforcement Training Center (FLETC), the national training institute that developed the use-of-force continuum, has made clear that, because of the formulaic nature of the continuum, it “directly conflicts with” Graham’s conception that “ ‘reasonableness under the Fourth Amendment is not capable of precise definition or mechanical application’ ”, and as a result, FLETC has “done away with the use-of-force continuum” in its own training materials, although many law enforcement agencies around the country still use some form of the continuum in their training programs.].) 15 Venegas v. County of Los Angeles (2004) 32 Cal.4th 820, 839-840 [11 Cal.Rptr.3d 692, 87 P.3d 1] (<HOLDING>); see Mendoza, supra, 206 Cal.App.4th at page

A: recognizing availability of qualified immunity defense to  1983 claims asserted in the california courts
B: holding that defendants are not entitled to qualified immunity
C: holding qualified immunity defense unavailable to the united states in ftca action
D: holding that qualified immunity is an affirmative defense that must be pled by the official who claims it
A.