Those are the exact types of cases being addressed in courts right now and without exception (that i know of) the courts are finding that this is unreasonable and finding against the officer.

Courts are saying that taser use is reasonable to address a threat, but not to gain compliance when someone is passively resisting.

And to put things in perspective, there have only been a few instances (out of thousands of taser applications) where the person was "unable" to comply. One in Federal Way that was well publicized.