Graham v. Connor

490 U.S. 386 Supreme Court 1989

ifjudged from the perspective ofpolice officersforced to make split-second judgments -- in circumstances that are tense, uncertain, and rapidly evolving --the question is whetheranofficer'suseof forcewillan officer's good … whether the individual officers acted in "good faith" or "maliciously and sadistically for the very purpose of causing harm," is incompatible with a proper Fourth Amendment analysis. We do not agree with the Court of Appeals' suggestion, see 827 F.2d at 948, that the "malicious and sadistic" inquiry is merely another way of describing conduct that is objectively unreasonable under the circumstances.everbe"unreasonable"

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In North Carolina, police officers unjustly arrested Dethorne Graham, a diabetic Black man, who was suffering from an insulin reaction. The officers ignored his friend’s pleas to give him sugar as they placed him under arrest, cuffing his hand tightly around his back.

Graham filed suit alleging respondents had used excessive force, in violation of his Fourth, Eighth, and Fourteenth Amendment rights. The Supreme Court rejected Graham’s arguments, ruling that excessive use of force claims, whether deadly or not, must be evaluated under the “objectively reasonable” standard of the Fourth Amendment, the question being how would a reasonable officer have acted in that circumstance. The notion of what is objectively reasonable expands significantly if the accused officer perceived their life was at risk.

The criteria set out in this case was used to acquit four LA police officers after their brutal assault of Rodney King in 1991. The objectively reasonable standard set forth in *Graham v. Connor* has also been raised to defend police in the killings of Michael Brown, Samuel DuBose, Jamar Clark, Keith Lamont, George Floyd, and many others.