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[–] dampkitty ago 

Yes they can

http://www.mncourts.gov/mncourtsgov/media/High-Profile-Cases/27-CR-20-12951-TKL/Exhibit67807072020.pdf

"Test of Proportionality Neck Restraints (conscious or unconscious applications) shall only be used against subjects when lower force Options either: Have failed, Will likely fail."

You can't just handcuff someone and then go get a coffee, he'd just run away, secondary restraint is required when sub is resisting