Graham v. Connor—the “Graham Factors”

Deadly Force Overview

Graham v. Connor (US 1989) is the landmark US Supreme Court case that defines reasonable use of force by police officers in the line of duty.  All officers are taught about this case in the academy; most are periodically reminded of it throughout their careers.

In summary, Graham v. Connor holds this:

All claims that law enforcement officials have used excessive force—deadly or not—in the course of an arrest, investigatory stop, or other “seizure” of a free citizen, are properly analyzed under the Fourth Amendment’s “objective reasonableness” standard.

The “reasonableness” of a particular use of force must be judged from the perspective of a reasonable officer on the scene, rather than with the “20/20 vision of hindsight.”

 The test of reasonableness is not capable of precise definition or mechanical application.  Its proper application requires careful attention to the facts and circumstances of each particular case, including:

  1. The severity of the crime at issue,
  2. Whether the suspect poses an immediate threat to the safety of the officers or others, and
  3. Whether he is actively resisting arrest or attempting to evade arrest by flight.

The question is whether the “totality of the circumstances” justifies a particular use of force applied in the situation.  The most important factor is #2—whether the suspect poses an immediate threat to the safety of the officer or others.

These are commonly known as the “Graham Factors.”

An officer’s actual intent is irrelevant as to whether force was excessive.  “An officer’s evil intentions will not make a Fourth Amendment violation out of an objectively reasonable use of force; nor will an officer’s good intentions make an objectively unreasonable use of force constitutional.”

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