Facts of the case: Petitioner Graham asked for the assistance of his friend with a purchase of orange juice. The petitioner has diabetes and needed the juice to counter an insulin reaction. They drove to a store, but the lines were too crowded, so they left in a hurry (Graham v. Connor, 1989). The respondent Connor, an officer, took a note of their “suspicious” behavior and stopped them. The petitioner resisted the arrest, attempting to explain his condition, but was ignored and suffered several injuries. A backup officer arrived shortly after, handcuffing Graham. He filed a suit, accusing the officers of using excessive force with “malicious and sadistic” intent to cause harm.
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Issue: Whether using force was excessive and the need to find a “sadistic and malicious” intent applies as legitimate criteria to judge an officer’s decisions.
Rule of the court: The court rejected the case, ruling that the “reasonableness” factor under the Fourth Amendment was alone a sufficient way to judge an officer’s actions.
Held: Any claim about a police officer using excessive force during an arrest or stop must be viewed under the Fourth Amendment’s standards specifically. The Fourth Amendment’s standard of “reasonableness” fulfills the need to judge the officer’s actions. The “malicious and sadistic” intent, therefore, does not negate the “reasonableness” factor.
Analysis: The court’s judgment that the used force was reasonable and not excessive raises many potential issues. While the officer had legal criteria to stop and check the petitioner’s actions due to the suspicious behavior, the use of force seems excessive if the arrested attempted to cooperate and explain the situation. Although the attempted resistance may call for a backup or arrest, the use of force that leads to several bruises and broken bones seems hardly reasonable. The criteria for judging the use of force as “reasonable” needs an overhaul to take into account potential threats from the suspected person and the officer’s duty to avoid causing unnecessary harm.
Conclusion: The case became the basis for many other cases with police force elements used during the arrest. The supporters of the ruling cite it as a way for officers to stop the dangerous situation from escalating further. The opposing side highlights how it led to several notorious cases where the citizens died due to excessive force and that potential racial biases should be considered when judging the officer’s actions.
Graham v. Connor, 490 U.S. 386 (1989). Citing a Supreme Court case available in United States Reports.
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