Being able to refer to trained techniques as opposed to "street-fighting" techniques in reporting a use of force makes it easier to show the officer's use of force was objectively reasonable under the circumstances. this is a requirement under what court case?

It was under Graham v Connor case. Someone explained that the defense attorney made the jury think the officer tried to hide his use of force behind a smoke screen of clinical language and that he did so to minimize brutality. Also, law enforcement trainers use such jargon to make communication within the profession more concise and efficient. To make use of clinical-sounding terms, there are two reasons behind it 1. Is to make a precise description and 2. Different between trained and street fighting techniques.