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Graham v. Connor | 490 U.S. 386 (1989)

When a diabetic has an insulin reaction, his body systems start shutting down and he collapses into shock. But consider Dethorne Graham. His insulin reaction led to far more shocking consequences and to the case of Graham versus Connor.

Graham knew his blood sugar was dangerously low. His friend Berry drove Graham to a store where he could buy sugary orange juice. Graham entered the store, but he left immediately after seeing the lengthy checkout line, and asked Berry to take him elsewhere. Observing this hasty exit and guessing that Graham had robbed the store, police officer M. S. Connor stopped Graham and began questioning him.

Graham moved erratically. Soon, he swooned and fell to the sidewalk. Berry explained that his friend was having a reaction and desperately needed sugar, but Connor believed Graham was just drunk. Backup officers arrived and helped Connor handcuffed Graham. They slammed him into the police car's hood and shoved him inside. They released Graham only after learning that the store hadn't been robbed.

Graham suffered serious injuries from this encounter. He filed a section 1983 action accusing Connor and the other officers of violating the Fourth Amendment's ban on unreasonable searches and seizures. The district court dismissed the case and the Fourth Circuit affirmed. Both courts held that Graham failed to show that the officers were maliciously or sadistically motivated. Graham appealed to the Supreme Court.

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