The U.S. Supreme Court case Graham v. Connor, 1988, centered on the issue of excessive force by law enforcement and how it should be constitutionally evaluated under the Fourth Amendment's "objective reasonableness" standard. Dethorne Graham, a diabetic man, was forcibly detained by police officers led by Officer M.S. Connor after a rapid exit from a convenience store raised suspicion of criminal activity; no crime had been committed though. During his detention, Graham sustained injuries and subsequently filed suit alleging that the officers used excessive force violating his constitutional rights under Amendments IV (unreasonable seizures) and XIV (due process). The court held that claims of excessive force during an arrest or investigatory stop should be analyzed under the Fourth Amendment rather than substantive due process principles because such incidents are more appropriately characterized as seizures instead of denials of liberty without due process.

In the dissenting opinion for Graham v. Connor, Justice Blackmun argued that a more specific standard should be used to evaluate excessive force claims against law enforcement officers under the Fourth Amendment. He criticized the majority's decision to apply an "objective reasonableness" standard, arguing it was too vague and could potentially allow for police misconduct in certain situations. Instead, he proposed a test that would consider whether the officer had acted in good faith and whether his or her actions were proportional to the threat faced. By focusing on these factors, Blackmun believed this approach would better balance individuals' rights with law enforcement needs while also providing clearer guidance for courts evaluating such cases.