The stop
An officer stops the car after Graham leaves a store quickly.S1 ↗
Police force is judged by 'objective reasonableness' from the officer's perspective, not with 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 ↗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 ↗
Excessive force is a seizure question.
Charlotte police and the power it used. The people on the citizen side are named as the case names them and are not scored.
The standard for police force.
Graham (1989) set the standard; qualified-immunity cases (Harlow, Pearson) shield officers from it.
All-time consequence · very high. Pointed against the citizen.
Power level from the earlier version of this page. Band 79–86 · ±4 uncertainty.
institution-protective · 0.5Remanded under a new standard
Standard favors the officer's view
The governing standard. Allowance for the moment.S1 ↗
The opinions and records behind every line on this page.
Rehnquist, C.J., for the Court; Blackmun, J., concurring in part and in the judgment (with Brennan, Marshall). Argued 21 Feb 1989, decided 15 May 1989.
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Each entry opens the court's own words, a plain reading and the limit of the rule.
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Claims that police used excessive force during a seizure are judged under the Fourth Amendment's objective reasonableness standard, from the perspective of a reasonable officer on the scene.
…from the perspective of a reasonable officer on the scene, rather than with the 20/20 vision of hindsight.S1 · Justia · U.S. Reports ↗
Applied deferentially in later cases.
Links to places on the map where a record shows this rule was applied. It links; it doesn't color the map.
Charlotte police and the power it used. The people on the citizen side are named as the case names them and are not scored.
Charlotte, North Carolina
national — every police seizure
The dispute began in Charlotte, North Carolina.
The scored institution: Charlotte police.
Links to related places on the map.
On its own, it doesn't change any county's score.
| case_ref | case:graham-v-connor |
|---|---|
| Event type | adjudicated_case |
| Location | Charlotte, North Carolina |
| Scale | IV · Institutional · national |
| Direction | −1 · institution-protective |
| Gravity · Current force | 90 · 95 |
| Method | civic3-gravity-1.0 |
Who won each encounter, from the sources on this page.
| Encounter | What was at stake | Taken by | What changed |
|---|---|---|---|
| 1989-05-15 · Supreme Court of the United States · 490 U.S. 386 (1989) | What standard governs excessive-force claims during a seizure? | SPLIT | vacated and remanded; officer-perspective standard set. S1 ↗ |
Split 1 · a count of results, not a score
Gravity, current force and effect use the Civic³ method on the Equation page. Every input below shows its reason and source. Challenge any of them.
The six components below, weighted and summed.
G = .25 Authority + .20 Reach + .20 Durability + .15 Progeny + .10 Cross-domain + .10 Implementation| Input | Score | Weight | Contribution | Reason |
|---|---|---|---|---|
| Authority | 90 | 25% | 22.50 | A Court without dissent on the standard.S1 ↗ |
| Reach | 95 | 20% | 19.00 | Every police seizure.S1 ↗ |
| Durability | 95 | 20% | 19.00 | Still the standard.S1 ↗ |
| Progeny | 95 | 15% | 14.25 | Every excessive-force case.S1 ↗ |
| Cross-domain | 60 | 10% | 6.00 | Policing nationwide.S1 ↗ |
| Implementation | 90 | 10% | 9.00 | Applied in courts daily.S1 ↗ |
| Total | 100% | 89.75 | Displayed as 90 |
Sets a standard read deferentially to officers; Graham himself won a remand. Low confidence.
E = −1 × 90 × 0.5 × 95/100Controlling.
| Field | This file | Meaning |
|---|---|---|
| Power level /99 | 83 · band 79–86 | From the earlier version (an editorial estimate). |
| Legal / Promise / Divergence | 62 / 82 / 20 | Remedy delivered versus constitutional promise. |
| Battle Power (citizen / institution) | 55 / 62 | Litigation strength of each side, from the five inputs above. |
| Gravity | 90 | All-time constitutional consequence. |
| Current force | 95 | How much of that weight still governs today. |
| Constitutional Effect | −42.6 | Signed present consequence. |
Values from the earlier version.
| Field | Legacy file | This edition |
|---|---|---|
| Power level | 83 · band 79–86 | 83 (carried) |
| Legal / Truth | 62 / 82 | Shown as the Legal and Promise games. |
The legacy page was rebuilt on the case-record chassis.
The old page's write-up is carried in, checked against the opinion.
Graham's injuries in detail.
The outcome on remand.
The Fourth Circuit's test (described here from the opinion summary).
Every number, quote and edge on this page can be challenged with a source.