As the Supreme Court stated in
Graham v. Connor, “[i]n addressing an excessive force claim brought under
§ 1983, analysis begins by identifying the specific constitutional right allegedly infringed by the challenged application of force.”
490 U.S. 386, 394, 109 S.Ct. 1865, 104 L.Ed.2d 443 (1989).
Connor held that “
all claims that law enforcement officers have used excessive force—deadly or not—in the course of an arrest, investigatory stop, or other ‘seizure’ of a free citizen should be analyzed under the Fourth Amendment and its ‘reasonableness' standard.”
Id. at 395, 109 S.Ct. 1865. Thus, “[d]etermining whether the force used to effect a particular seizure is ‘reasonable’ under the Fourth Amendment requires a careful balancing of the nature and quality of the intrusion on the individual's Fourth Amendment interests against the countervailing governmental interests at stake.”
Id. at 396, 109 S.Ct. 1865. (internal quotation omitted). The determination of “reasonableness” under the Fourth Amendment is “not capable of precise definition or mechanical application ... [but] requires careful attention to the facts and circumstances of each particular case, including the severity of the crime at issue, whether the suspect poses an immediate threat to the safety of the officers or others, and whether he is actively resisting arrest or attempting to evade arrest by flight.”
Id. (internal quotation omitted). The Court went on to explain that, “[a]s in other Fourth Amendment contexts, however, the ‘reasonableness' inquiry in an excessive force case is an objective one: the question is whether the officers' actions are ‘objectively reasonable’ in light of the facts and circumstances confronting them.”
Id. at 397, 109 S.Ct. 1865.