With no explanation, chose the best option from "A", "B", "C" or "D". and crashing. Id. at 1327. The court determined the persons to be stopped in the vehicle were “stopped by the very instrumentality set in motion ... to achieve that result,” when an officer fired his weapon to stop the passenger and driver, and one of those bullets struck the passenger. Id. at 1329. But, unlike Vaughan, a significant difference exists here because the instrumentality meant to stop Mr. Brooks — the bullet from Deputy Gaenzle’s gun — did not stop him, and therefore, the intended result was not achieved. We are not alone in interpreting Supreme Court precedent as requiring intentional termination of movement or acquisition of physical control in flight situations, regardless of the force applied. See, e.g., United States v. Bradley, 196 F.3d 762, 768 (7th Cir.1999) (<HOLDING>); United States v. Hernandez, 27 F.3d 1403,

A: holding force to be an element of pre1994 amendment  111 which may be satisfied by proof of force or threat of force
B: holding there must be either a show of authority or a use of force which must have caused the fleeing individual to stop attempting escape
C: holding that an officer may use deadly force when a fleeing suspect threatens the officer with a weapon
D: holding that an arrest requires either physical force  or where that is absent submission to the assertion of authority
B.