Graham v. Connor
Citation: 490 U.S. 386 (1989) Court: United States Supreme Court
Facts
Dethorne Graham, a diabetic, asked his friend Berry to drive him to a convenience store to get orange juice during a hypoglycemic episode. Seeing the store crowded, he rushed out and Berry drove away. Officer Connor became suspicious, stopped the car, and ordered Graham and Berry to wait while he investigated. Graham got out of the car, ran around it twice, and passed out. Officers handcuffed him, ignored his attempts to explain his medical condition, and shoved his face into the hood of the car. Graham sustained injuries and sued under 42 U.S.C. § 1983.
Issue
What constitutional standard governs claims of excessive force by law enforcement during an investigatory stop or arrest?
Holding
The Supreme Court held that all claims of excessive force by law enforcement in the context of an arrest, investigatory stop, or other seizure of a free citizen are governed by the 4th Amendment’s objective reasonableness standard, not by substantive due process.
Rule / Doctrine
Excessive force claims against law enforcement are analyzed under the 4th Amendment’s objective reasonableness standard. The reasonableness of force is judged from the perspective of a reasonable officer on the scene, without the benefit of hindsight, and taking into account factors such as: (1) the severity of the crime, (2) whether the suspect poses an immediate threat, and (3) whether the suspect is actively resisting or evading arrest. Substantive due process is not the governing framework when a more specific constitutional provision applies.
Significance
Graham v. Connor unified excessive force jurisprudence under the 4th Amendment and eliminated the use of substantive due process as the governing standard for police use-of-force claims. The “objective reasonableness” test it established remains the dominant framework in police liability litigation today. See also Scott v. Harris for application of the Graham standard in a high-speed chase context.