What constitutes a "reasonable" amount of force will vary depending on the circumstances surrounding the arrest. Cyrus v. Town of Mukwonago, 624 F.3d 856, 861 (7th Cir. 2010) (citing Graham, 490 U.S. at 396); see also Cox v. Hurd, No. 07-CV-6044, 2009 WL 539860, at *3 (W.D.N.Y. Mar. 4, 2009) (listing relevant factors). While a determination of whether the force used was reasonable may sometimes present an issue of fact for the jury, see, e.g., Tracy v. Freshwater, 623 F.3d 90, 98-99 (2d Cir. 2010); Maxwell v. City of New York, 380 F.3d 106, 109-10 (2d Cir. 2004), courts have also held that "under the Fourth Amendment's reasonableness standard, excessive-force claims generally require at least deminimis physical injury."