A private person can use non-deadly force to make a citizen's arrest. This non-deadly force has to be reasonable and appropriate to the situation, though. It cannot be more than what is reasonably believed to be necessary to make the arrest or prevent an escape. A private person can only use deadly force to make a citizen's arrest in very rare cases. They have to reasonably think deadly force is necessary to defend themselves or someone else from deadly harm. Example: David is standing in the lobby of the police station when Ray runs past. David hears someone shout “stop that man!” Rather than running after Ray, David draws a pistol and shoots him. David's citizen's arrest has used excessive force.