A lot depends on the cows and the AI Tech.. In the past, I have pinched a cow up in a corner with a bucket of grain and 2 panels. (If they are real gentle.) Or in a panel alley way with a 2x4 in front and back. Even tied one to a post for the Tech one night in the dark. He got her done!
My current vet that AI's for me won't touch them unless they are in the chute with their head caught.