Law School Case Brief
Graham v. Connor - 490 U.S. 386, 109 S. Ct. 1865 (1989)
Determining whether the force used to effect a particular seizure is "reasonable" under the Fourth Amendment requires a careful balancing of the nature and quality of the intrusion on the individual's Fourth Amendment interests against the countervailing governmental interests at stake. The test of reasonableness is not capable of precise definition or mechanical application, however, its proper application requires careful attention to the facts and circumstances of each particular case, including the severity of the crime at issue, whether the suspect poses an immediate threat to the safety of the officers or others, and whether he is actively resisting arrest or attempting to evade arrest by flight
A diabetic filed a 42 U.S.C.S. § 1983 action against respondent law enforcement officers to recover damages for injuries he sustained when physical force was used against him during an investigatory stop, while he was on his way to obtain orange juice to counteract the onset of an insulin reaction. The appellate court endorsed the four-factor test applied by the trial court. The diabetic argued that it was error to require him to prove that the excessive force used against him was applied maliciously and sadistically to cause harm.
Did the appellate court err in using the substantive due process standard in analyzing diabetic’s claims?
The Court vacated the judgment, holding that the diabetic's claims should have been analyzed under the Fourth Amendment's objective reasonableness standard, rather than under a substantive due process standard. The proper Fourth Amendment inquiry was one of objective reasonableness under the circumstances, and subjective concepts like malice and sadism had no proper place in that inquiry.
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