Graham v. Connor

Diabetic Graham (plaintiff), experiencing an insulin reaction, was forcibly detained, handcuffed, and shoved against a car by Officer Connor (defendant) and backup officers during an investigatory stop after Connor grew suspicious watching Graham rush in and out of a convenience store; the officers refused to give Graham sugar or check his diabetic identification, and Graham suffered a broken foot and shoulder injury before being released once Connor learned nothing had happened at the store. Graham sued under section 1983 for excessive force; the district court applied a four-factor substantive due process test and granted a directed verdict for Connor, the court of appeals affirmed, and the Supreme Court granted certiorari.