Graham Vs Connor
This case established the legal principle of Objective Reasonableness
Graham v. Connor, a pivotal U.S. Supreme Court case decided in 1989, set a significant precedent in the realm of police use of force and its evaluation under the Fourth Amendment. The case arose when Dethorne Graham, a diabetic, experienced an insulin reaction and asked a friend to drive him to a convenience store. Upon observing Graham's hasty exit from the store, Officer Connor suspected him of criminal activity and stopped the car. Despite being informed of Graham's medical condition, the officers handcuffed him, leading to physical injuries (Legal Dictionary, n.d.).
Graham filed a lawsuit under 42 U.S.C. 1983, alleging excessive force by the officers. The District Court, applying a "substantive due process" standard, ruled against Graham. The Fourth Circuit Court of Appeals affirmed this decision. However, the Supreme Court reversed these rulings, holding that excessive force claims in the context of police stops or arrests should be evaluated under the Fourth Amendment's "objective reasonableness" standard, not a substantive due process standard (Justia, n.d.; Casetext, n.d.).
The Supreme Court's decision emphasized that the reasonableness of a particular use of force must be judged from the perspective of a reasonable officer on the scene rather than with the 20/20 vision of hindsight. This standard acknowledges that officers often must make split-second decisions in tense, uncertain, and rapidly evolving situations (Legal Dictionary, n.d.).
This ruling has profoundly impacted how courts assess police conduct, specifically regarding the use of force. It shifted the focus from a generic substantive due process standard to a more precise analysis under the Fourth Amendment, which deals with protections against unreasonable searches and seizures (Legal Dictionary, n.d.).
For further reading, please refer to the following sources:
Legal Dictionary. (n.d.). Graham v. Connor - Case Summary and Case Brief. Retrieved from https://legaldictionary.net/graham-v-connor/
Justia. (n.d.). Graham v. Connor, 490 U.S. 386. Retrieved from https://supreme.justia.com/cases/federal/us/490/386/
Casetext. (n.d.). Graham v. Connor, 490 U.S. 386. Retrieved from https://casetext.com/case/graham-v-connor-5
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About the Author: Professor Mike is a writer, editor, and teacher. He is also a veteran and retired law enforcement executive.