Police use of force Flashcards
Graham v. Connor,
Facts
In November 1984, Dethorne Graham, a diabetic, experienced an insulin reaction and asked his friend William Berry to drive him to a convenience store to purchase orange juice. Upon seeing a long line, Graham hurriedly left the store and asked Berry to drive him to a friend’s house instead. Officer Connor of the Charlotte, North Carolina, Police Department observed Graham’s actions and, suspecting something was amiss, followed Berry’s car and made an investigative stop. Despite Berry explaining that Graham was having a “sugar reaction,” Connor detained them to verify the situation. In the ensuing events, multiple officers arrived, and Graham was subjected to physical force, including being handcuffed tightly, mocked, shoved against a car, and thrown into a police car, despite his pleas and Berry’s attempts to explain his medical condition. Graham was eventually released without charges but sustained significant injuries. He filed a lawsuit under 42 U.S.C. § 1983, claiming the officers used excessive force in violation of his Fourth and Fourteenth Amendment rights.
Issue
The main issue before the Supreme Court was determining the appropriate constitutional standard for evaluating a free citizen’s claim that law enforcement officials used excessive force in the course of making an arrest, investigatory stop, or other “seizure” of his person.
Holding
The Supreme Court held that claims of excessive force by law enforcement officials in the course of an arrest, investigatory stop, or other “seizure” should be analyzed under the Fourth Amendment’s “objective reasonableness” standard, rather than under a substantive due process approach.
Tennessee v. Garner
Facts
On the night of October 3, 1974, Memphis Police Officers Elton Hymon and Leslie Wright responded to a reported burglary. Officer Hymon encountered Edward Garner, a 15-year-old suspect, who attempted to flee the scene. Despite observing that Garner appeared unarmed and posed no immediate threat, Hymon fatally shot Garner to prevent his escape. This action was supported by a Tennessee statute allowing police to use deadly force to prevent the escape of suspected felons. Garner’s father subsequently filed a lawsuit under 42 U.S.C. § 1983, claiming violations of his son’s constitutional rights.
Issue
The central issue before the Supreme Court was whether the use of deadly force against an unarmed, nonviolent fleeing suspect is constitutionally permissible under the Fourth Amendment, which protects against unreasonable searches and seizures.
Holding
The Supreme Court held that the use of deadly force to prevent the escape of an unarmed, nonviolent fleeing suspect violates the Fourth Amendment. The Court ruled that such force may only be used if the officer has probable cause to believe the suspect poses a significant threat of death or serious physical injury to the officer or others.
Scott v. Harris
Facts
In March 2001, Victor Harris led police on a high-speed chase after a deputy clocked him speeding and attempted to pull him over.
Deputy Timothy Scott joined the pursuit, which involved speeds exceeding 85 miles per hour on two-lane roads and various dangerous maneuvers by Harris.
After about six minutes and nearly ten miles, Scott decided to end the chase by using his push bumper to hit the rear of Harris’s vehicle, causing Harris to lose control, crash, and subsequently become quadriplegic.
Harris sued Scott under 42 U.S.C. § 1983, alleging excessive force resulting in an unreasonable seizure under the Fourth Amendment.
Issue
The central issue before the Supreme Court was whether Deputy Scott’s actions to terminate the high-speed chase by forcibly stopping Harris’s car violated the Fourth Amendment’s prohibition against unreasonable seizures.
Holding
The Supreme Court held that Deputy Scott’s actions were reasonable under the Fourth Amendment, granting him qualified immunity and entitling him to summary judgment. The Court reversed the decision of the Eleventh Circuit.
