Handcuffing a person on reasonable suspicion just to protect the officer’s safety and maintain the status quo is not unreasonable. United States v. Mayfield, 2020 U.S. Dist. LEXIS 520 (D. Neb. Jan. 3, 2020).
While the exclusionary rule can apply to forfeiture proceedings instigated by unreasonable border seizures because they are quasi criminal proceedings, United States v. Modes, Inc., 16 C.I.T. 189, 787 F. Supp. 1466, 14 Int’l Trade Rep. (BNA) 1124 (Ct. Int’l Trade 1992), this case does not involve a Fourth Amendment seizure, so Modes doesn’t apply. United States v. Harvic Int’l, 2020 Ct. Intl. Trade LEXIS 1 (Ct. Int’l Trade Jan. 3, 2020).