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Keywords

appealplealeasesustainedseizure

appealverdictmotionwilldue processseizuremotion for directed verdict

Related Cases

Graham v. Connor, 490 U.S. 386, 109 S.Ct. 1865, 104 L.Ed.2d 443, 57 USLW 4513

Facts

Dethorne Graham, a diabetic, requested a friend to drive him to a convenience store to buy orange juice to counteract an insulin reaction. After seeing a long line, he left the store and asked to be taken to a friend's house. Officer Connor, suspicious of Graham's behavior, conducted an investigatory stop, during which Graham was handcuffed and sustained injuries despite attempts to explain his medical condition. The officers ignored pleas for assistance and released him only after determining he had done nothing wrong.

On November 12, 1984, Graham, a diabetic, felt the onset of an insulin reaction. He asked a friend, William Berry, to drive him to a nearby convenience store so he could purchase some orange juice to counteract the reaction.

Issue

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

This case requires us to decide 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.

Rule

Claims of excessive force by law enforcement officials during an arrest or investigatory stop are analyzed under the Fourth Amendment's 'objective reasonableness' standard.

Held: All claims that law enforcement officials have used excessive force—deadly or not—in the course of an arrest, investigatory stop, or other 'seizure' of a free citizen are properly analyzed under the Fourth Amendment's 'objective reasonableness' standard, rather than under a substantive due process standard.

Analysis

The Supreme Court determined that the lower courts had incorrectly applied a four-factor test from Johnson v. Glick, which focused on the subjective motivations of the officers. Instead, the Court emphasized that the reasonableness of the force used must be judged from the perspective of a reasonable officer on the scene, considering the facts and circumstances without regard to the officers' intent.

Because petitioner's excessive force claim is one arising under the Fourth Amendment, the Court of Appeals erred in analyzing it under the four-part Johnson v. Glick test.

Conclusion

The Supreme Court vacated the judgment of the Court of Appeals and remanded the case for reconsideration under the Fourth Amendment's 'objective reasonableness' standard.

The Court of Appeals reviewed the District Court's ruling on the motion for directed verdict under an erroneous view of the governing substantive law, its judgment must be vacated and the case remanded to that court for reconsideration of that issue under the proper Fourth Amendment standard.

Who won?

The petitioner, Dethorne Graham, prevailed as the Supreme Court ruled in his favor, establishing that his excessive force claim should be evaluated under the Fourth Amendment.

The majority ruled first that the District Court had applied the correct legal standard in assessing petitioner's excessive force claim.

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