Graham v. Connor
104 L. Ed. 2d 443 · Supreme Court of the United States · 1989
Facts
Dethorne Graham, a diabetic, experienced an insulin reaction and asked his friend, William Berry, to drive him to a store for orange juice. After leaving the store quickly due to a long line, Officer Connor became suspicious and initiated an investigatory stop. Despite Berry explaining Graham's condition, officers ordered them to wait. Graham then exited the car, ran around it, and briefly passed out on the curb. Arriving backup officers cuffed Graham, ignored pleas for sugar, and made derogatory remarks about his condition. They then forced him onto Berry's car hood and into a police car, refusing him orange juice. Graham sustained a broken foot, cuts, a bruised forehead, and an injured shoulder during the encounter before being released after police confirmed he had done nothing wrong.
Procedural history
Graham filed an action under 42 U.S.C. § 1983, alleging excessive force in violation of his Fourteenth Amendment rights. The District Court granted a directed verdict for the officers, applying a four-factor test that included whether force was applied maliciously or sadistically. A divided panel of the Court of Appeals for the Fourth Circuit affirmed, endorsing the District Court's test. The Supreme Court granted certiorari and reversed the Court of Appeals' decision.
Issue
What constitutional standard governs a free citizen’s claim that law enforcement officials used excessive force in the course of making an arrest, investigatory stop, or other “seizure” of his person?
Holding
The Court held that claims of excessive force by law enforcement officials during an arrest, investigatory stop, or other seizure of a free citizen are properly analyzed under the Fourth Amendment’s “objective reasonableness” standard, not a substantive due process standard.
Rule
All claims that law enforcement officers used excessive force in the course of an arrest, investigatory stop, or other “seizure” of a free citizen must be analyzed under the Fourth Amendment’s “objective reasonableness” standard. This standard requires balancing the intrusion on Fourth Amendment interests against governmental interests, considering factors like the severity of the crime, whether the suspect poses an immediate threat, and whether they are resisting or evading arrest. The reasonableness of force must be judged from the perspective of a reasonable officer on the scene, without regard to their underlying intent or motivation, as the inquiry is objective.
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