Graham v. Connor
Headline: Police use-of-force claims during arrests and stops are governed by the Fourth Amendment's objective reasonableness test, changing how officers’ actions are judged and limiting broader due-process claims.
Holding: The Court holds that claims of excessive force during arrests or investigatory stops must be analyzed under the Fourth Amendment’s objective reasonableness standard, not under a generalized substantive due process test.
- Police actions during stops judged by Fourth Amendment objective reasonableness.
- Limits use of a general due-process test for prearrest force claims.
- Requires lower courts to re-evaluate excessive force cases under the new standard.
Summary
Background
A diabetic man suffered an insulin reaction, hurried out of a convenience store, and was stopped by a Charlotte police officer. Several officers restrained him, placed him face down on a car hood, refused assistance from friends, and later released him after learning he had done nothing wrong. The man sued the officers under a federal civil-rights statute, claiming excessive force; lower courts applied a four-factor due-process test and entered judgment for the officers, and the case reached this Court.
Reasoning
The Court addressed one main question: what constitutional standard governs claims that officers used excessive force during an arrest or investigatory stop. The Court held that such claims are evaluated under the Fourth Amendment's objective reasonableness test. That test balances the intrusiveness of the officers' actions against government safety needs, looks at the totality of circumstances (severity of the suspected offense, immediate threat, resistance or flight), and asks whether a reasonable officer on the scene would find the force justified. The Court rejected the older four-part substantive due-process test for these prearrest seizures and said subjective intent like malice is not central to Fourth Amendment reasonableness.
Real world impact
Moving forward, lawsuits about police force during stops and arrests will be judged by the Fourth Amendment's facts-and-circumstances reasonableness test, which allows police some split-second judgment but can still find force unreasonable. The Court vacated the lower-court judgment and sent the case back for reconsideration under the proper Fourth Amendment standard. The opinion left open some questions about excessive force after arrest and the role of other constitutional protections.
Dissents or concurrances
Justice Blackmun, joined by Justices Brennan and Marshall, agreed with the result but urged caution about foreclosing use of substantive due process in other prearrest cases, and would reserve that question for a later case.
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