CIVIC3CASE FILE · ADJUDICATED BATTLE
UNITED STATES · SUPREME COURT · POLICE FORCE

GRAHAM v. CONNOR

Police force is judged by 'objective reasonableness' from the officer's perspective, not with hindsight.

490 U.S. 386 / DECIDED 15 MAY 1989 / REHNQUIST, C.J.
CASE1989ADJUDICATED · U.S.
01 / Verdict · where it standsUS · 1989 · CASE
Outcome · vacated and remanded; officer-perspective standard set

THE 20/20 VISION OF HINDSIGHT.

Graham, a diabetic, felt an insulin reaction and had a friend drive him to a convenience store for orange juice; seeing a long line, he left quickly. A Charlotte officer, Connor, followed and stopped the car; backup officers handcuffed Graham and ignored his condition, and he was injured. The Court held that excessive-force claims in a seizure are judged under the Fourth Amendment's objective reasonableness standard, from the perspective of a reasonable officer on the scene, rather than with the 20/20 vision of hindsight, allowing for split-second judgments.

Graham's claim was sent back, not lost.S1 ↗
ϟ THE CASE IN 20 SECONDS
1WHOA diabetic man, against Charlotte police officers.
2WHATHow courts judge whether police used excessive force.
3WHY IT MATTERSThe standard for nearly every excessive-force case since, and one courts read deferentially.
THE FULL CASE FILE · the original write-up, checked
ORANGE JUICE

Graham, a diabetic, felt an insulin reaction coming on and asked a friend to drive him to a convenience store for orange juice. Seeing a long line, he left in a hurry and asked to go to another friend's house instead. A Charlotte officer, Connor, saw him leave hastily, followed and stopped the car. Backup officers handcuffed Graham and did not address his condition; he was injured, and released once the officer learned nothing had happened at the store.

On 15 May 1989 the Court held that excessive-force claims arising from a seizure are analyzed under the Fourth Amendment's objective reasonableness standard, not substantive due process: the force must be judged from the perspective of a reasonable officer on the scene, rather than with the 20/20 vision of hindsight, allowing for the fact that police officers are often forced to make split-second judgments. The officer's subjective intent is irrelevant. The case was sent back to be decided under that standard.S1 ↗

GRAHAM V. CONNOR
ILLUSTRATION · NOT A HISTORICAL IMAGE
♟ CITIZEN LOADOUT · GRAHAM
⬟
FOURTH AMENDMENT GOVERNS

Excessive force is a seizure question.

♜ INSTITUTION LOADOUT · CHARLOTTE POLICE
♜
THE SCORED ACTOR

Charlotte police and the power it used. The people on the citizen side are named as the case names them and are not scored.

WHAT THIS RULING DID NOT DO — Graham's claim was sent back, not lost. Subjective intent is irrelevant either way. Applied deferentially in later cases.
AFTERMATH LEDGER
WhenWhat happened
Lower courtsOfficers win. The Fourth Circuit affirms for the officers under a due-process test.S1 ↗
15 May 1989Vacated. Rehnquist for the Court sets the Fourth Amendment standard.S1 ↗
WHY THIS SITS WHERE IT DOES

The standard for police force.

THE THROUGH-LINE

Graham (1989) set the standard; qualified-immunity cases (Harlow, Pearson) shield officers from it.

90/100

CONSTITUTIONAL GRAVITY

All-time consequence · very high. Pointed against the citizen.