In Graham v.O'Connor (1989),involving the arrest of a diabetic who was suffering from an insulin reaction,the Supreme Court held that claims of excessive force in the course of making an arrest are to be analyzed under:

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The Supreme Court held in Graham v. Connor that claims of excessive force in the course of making an arrest are to be analyzed under the Fourth Amendment's "objective reasonableness" standard, which balances the nature and quality of the intrusion on the individual's Fourth Amendment interests against the countervailing governmental interests at stake. This standard focuses on the reasonableness of the officer's actions under the circumstances, rather than the officer's subjective intentions or the severity of the injury caused.

In Graham V