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Graham v. Connor

United States Supreme Court
 490 U.S. 386 (1989)


Graham (plaintiff) is diabetic. He had an insulin reaction on the day in question, and his friend Berry drove him to a store to buy juice. There was a long line at the store so Graham rushed out and asked Berry to drive him to a friend’s house. Officer Connor (defendant) became suspicious after seeing Graham rush in and out of the store and pulled Berry’s car over to make an investigative stop. Berry explained that Graham was having an insulin reaction, but Connor told them to wait there until he found out if something happened at the store. When backup arrived, Graham was handcuffed and shoved against the hood of Berry’s car face down. The officers refused to give Graham sugar and ignored his request that they check his wallet for his diabetic decal. During the incident, Graham sustained several injuries, including a broken foot and shoulder injury. He was finally released when Connor learned that nothing happened at the store. Graham sued Connor and the other officers under 42 U.S.C. §1983, charging them with using excessive force in violation of the Fourteenth Amendment. Connor moved for a directed verdict. The district court applied a four-factor test and granted Connor’s motion for directed verdict, finding that the force used was appropriate under the circumstances and applied in a good faith effort to restore order. The court of appeals affirmed. The Supreme Court granted certiorari.

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