Graham v. Connor

Dethorne Graham, who had diabetes, felt an insulin reaction and went to a convenience store for orange juice. Seeing a long line, he quickly left and asked his friend to drive elsewhere. Officer Connor saw the quick entry and exit, became suspicious, and made an investigatory stop.

Backup officers handcuffed Graham, ignored attempts to explain his medical condition, and Graham alleged injuries from the encounter. He sued under 42 U.S.C. § 1983 for excessive force.

The dispute reached the courts because the police action, prosecution, civil-rights claim, or government policy raised a constitutional question that could not be answered by the facts alone.

What constitutional standard governs a free citizen's claim that law enforcement used excessive force during an arrest, investigatory stop, or other seizure?

In plain English, the court had to decide where police authority ended and constitutional protection began under the facts of this case.

The Supreme Court held that excessive-force claims arising during an arrest, investigatory stop, or other seizure are analyzed under the Fourth Amendment's objective reasonableness standard, not a substantive due process standard under the Fourteenth Amendment.

The decision matters because graham became the central framework for police use-of-force cases. Courts ask what a reasonable officer on the scene would have understood under the facts and circumstances, allowing for tense, uncertain, rapidly evolving situations, while excluding the officer's subjective intent as the legal test.

In a police use-of-force case, the question is not whether the officer had good or bad intentions. The question is whether the force was objectively reasonable from the perspective of a reasonable officer facing the situation at the time.

Graham remains the baseline rule in Fourth Amendment excessive-force litigation, training, policy review, and civil rights cases involving arrests, stops, and other seizures.