Graham v. Connor

490 U.S. 386 (1989)

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Nature of the Case

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Facts

In this action under 42 U.S.C. 1983, Graham (P) seeks to recover damages for injuries allegedly sustained when law enforcement officers used physical force against him during the course of an investigatory stop. P, a diabetic, felt the onset of an insulin reaction. He asked a friend, William Berry, to drive him to a nearby convenience store so he could purchase some orange juice to counteract the reaction. Berry agreed, but when P entered the store, he saw a number of people ahead of him in the checkout line. Concerned about the delay, he hurried out of the store and asked Berry to drive him to a friend's house instead. Connor (D), a police officer saw P hastily enter and leave the store. The officer became suspicious that something was amiss and followed Berry's car. About one-half mile from the store, he made an investigative stop. Berry told D that P was simply suffering from a 'sugar reaction,' the officer ordered Berry and P to wait while he found out what, if anything, had happened. When D returned to his patrol car to call for backup assistance, P got out of the car, ran around it twice, and finally sat down on the curb, where he passed out briefly. A number of police officers arrived on the scene in response to D's request for backup. P was rolled over on the sidewalk and cuffed as the officers present ignored Berry's pleas to get P some sugar. Several officers then lifted P up from behind, carried him over to Berry's car, and placed him face down on its hood. Regaining consciousness, P asked the officers to check in his wallet for a diabetic decal that he carried. In response, one of the officers told him to 'shut up' and shoved his face down against the hood of the car. Four officers grabbed P and threw him headfirst into the police car. A friend of P's brought some orange juice to the car, but the officers refused to let him have it. D received a report that P had done nothing wrong at the convenience store, and the officers drove him home and released him. P sustained a broken foot, cuts on his wrists, a bruised forehead, and an injured shoulder; he also claims to have developed a loud ringing in his right ear that continues to this day. P sued under 42 U.S.C. 1983 against the individual officers alleging that they had used excessive force in making the investigatory stop, in violation of 'rights secured to him under the Fourteenth Amendment to the United States Constitution and 42 U.S.C. 1983.' At the close of P's evidence, Ds moved for a directed verdict. In ruling on that motion, the District Court considered the following four factors, which it identified as 'the factors to be considered in determining when the excessive use of force gives rise to a cause of action under 1983': (1) the need for the application of force; (2) the relationship between that need and the amount of force that was used; (3) the extent of the injury inflicted; and (4) 'whether the force was applied in a good faith effort to maintain and restore discipline or maliciously and sadistically for the very purpose of causing harm.' The District Court granted D's motion for a directed verdict. A divided panel of the Court of Appeals for the Fourth Circuit affirmed and endorsed the four-factor test applied by the District Court. The Supreme Court granted certiorari.