Graham v. Connor: Summary & Decision

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  • 0:01 The Incident
  • 2:00 The Case
  • 2:44 The Opinion
  • 3:52 The Graham Decision
  • 4:33 Lesson Summary
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Lesson Transcript
Instructor: Ashley Dugger

Ashley has a JD degree and is an attorney. She has taught and written various law courses.

The U.S. Supreme Court's decision in 'Graham v. Connor' established the test for what constitutes a police officer's legal use of force. This lesson explains that case and examines the ruling.

The Incident

Dethorne Graham didn't commit a crime, but his 1984 encounter with police officers left him with a broken foot, hurt shoulder, bruised forehead, and other injuries. So, what happened? Did the officers break the law? What are the rules regarding a police officer's use of force? Let's take a look at when an officer can legally use physical power on a suspect, and how much power can be used.

Graham was a diabetic and felt he was having an insulin reaction. Graham asked his friend, Berry, to drive him to a convenience store so that Graham could buy orange juice. Graham, like many diabetics, felt the sugar in the juice would counteract his reaction. Graham hurried into the convenience store but quickly exited because he saw that the checkout line was long. He got back in Berry's car, and the two left.

Charlotte Police Officer Connor was observing from across the street and thought Graham's actions were suspicious. The way Graham hurried in and out of the store made Connor think the two might be engaged in criminal behavior, such as stealing from the store.

Officer Connor followed Graham and Berry's car, pulling them over just a couple blocks from the store. Berry explained Graham's health situation, but Officer Connor felt the situation needed further investigation. He instructed Berry and Graham to stay in their car while he sent another officer back to the store to determine what had happened. However, Graham began acting strangely. He exited the car and ran around it twice, before sitting down on the curb and briefly passing out.

Backup officers arrived and, thinking Graham was drunk, handcuffed him. The officers forced Graham onto the car's hood, and then head first into the back seat of a police car. Though Graham regained consciousness and a friend arrived with the orange juice, the officers refused to give it to Graham. The officers also refused to check Graham's wallet for an emblem he insisted would prove he was diabetic.

Finally, the officer returned from the store to report that nothing had happened there. The officers drove Graham home and released him.

The Case

Graham then sued the officers for civil rights violations. His case was dismissed, because the court felt the officers had not acted 'maliciously and sadistically' in an attempt to injure Graham or violate his rights. Notice how the court applied a subjective standard, in that they judged whether or not Officer Connor and the other officers involved meant to, or tried to, injure Graham.

Graham then petitioned to have his case reviewed by the United States Supreme Court. The Court accepted his case and remanded the case, meaning they sent it back to the lower court, to be reconsidered. This time, the Supreme Court directed the lower court to use an objective standard. The test needed to be neutral and impartial, rather than based on the officers' actual thoughts and intentions.

The Opinion

The Supreme Court set a new standard that has since determined when, and to what extent, an officer can legally use force. Through the 1989 Graham decision, the Court established the objective reasonableness standard. This 'reasonableness' test is based on the Fourth Amendment guarantee against unreasonable search or seizure.

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