Week 5 - Case Brief
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Jan 9, 2024
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Running Head:
CASE BRIEF
Graham v. Conner (1989)
CRJ 103 – Criminal Procedure
Professor Lashunda Stateson
Graham v. Conner (1989) Case Brief
Facts
Dethrone Graham was a diabetic who felt the onset of an insulin reaction and asked his
friend to drive him to a convenience store to get some orange juice.
Conner, a city law
enforcement officer, viewed Graham’s hasty exit from the tore and stopped the car of
Berry.
Even though Berry informed the officer of the condition of Graham, Conner
informed the two to wait until he became familiar with what happened in the store, and in
the meantime, backup officers arrived on the scene.
Graham was handcuffed and thrown
on the hood of Berry’s car, and his attempt to explain Graham’s condition was ignored.
Once Officer Conner received a report that Graham had not committed any crimes at the
convenience store, he was driven home and released, but multiple injuries was sustained
by Graham because of this encounter.
Issue
Evaluating the claim of excessive force in the context of a law enforcement officer stop
or arrest, should a court use a substantive due process standard?
Court Decision
The United States Supreme Court ruling in this case was that excessive use of force
claims should be evaluated under the “objective reasonableness” standards of the Fourth
Amendment and not a substantive due process standard under the Fourteenth
Amendment. As such, the facts and conditions connecting to the use of force should be
the driving force of the analysis, rather than any inappropriate expectations or
inspirations by law enforcement officer using force.
The ruling in this case indicated that
excessive force by law enforcement officers should be judged under an “objective
reasonableness” standard.
In other words, the facts and circumstances relating to the use
of force should be the driving force of the analysis, instead of any improper intent or
motivation by the law enforcement officer who used force.
The ruling in this case
established that claims of excessive force by law enforcement officers should be judged
under an “objective reasonableness’ standard.
Holding
No. Excessive force claims based on the context of an investigatory stop and arrest
require examination under the Fourth Amendment and not substantive due process.
This
case clearly indicated that excessive force claims should be tied to a specific
constitutional provision, and that such claim should not be examined under single,
generic substantive due process standard.
Case Significance
Established in this case was the “objective reasonableness” standard for evaluating claims
of excessive force by law enforcement officers under the Fourth Amendment.
The
standards requires courts to evaluate the reasonableness of a law enforcement officer’s
use of force from the reasonable officer on the scene perspective, instead of the 20/20
vision hindsight.
Also, the case provided clarification that excessive force claims should
be associated with a specific constitutional provision, for instance the Fourth
Amendment, and not be analyzed under a single, generic substantive due process
standard (paperowls.com, 2023).
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References
Graham vs. Conner:
A landmark in understanding police use of force.
(2023).
Retrieved from
https://papersowls.com/example-Graham-vs-Conner-a-landmark-in-understanding-
police-use-of-force
.