In Graham v. Connor, 490 U.S. 386 (1989), Graham sought to recover damages for injuries allegedly sustained when law enforcement officers used physical force against him during an investigatory stop. Graham was diabetic, and was suffering from a "'sugar reaction'" at the time of the stop. The law enforcement officers involved in the stop did not initially believe that Graham was diabetic, and thought that he was drunk. (Id. at p. 389) Somehow, during the stop, Graham sustained a broken foot, cuts, and bruises. Graham alleged that the officers used excessive force during the stop (42 U.S.C.A. 1983). (Graham, at p. 390) The United States Supreme Court, in its analysis, 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 p. 395.) Further, "the 'reasonableness' of a particular use of force must be judged from the perspective of a reasonable officer on the scene, rather than with the 20/20 vision of hindsight. " (Id. at p. 396.) The California Supreme Court rejected the four-part, substantive due process test from Johnson and held that the proper test was one of reasonableness under the Fourth Amendment. (Id. at pp. 393-394.) The court explained that the analysis of excessive force claims brought under 1983 "begins by identifying the specific constitutional right allegedly infringed by the challenged application of force. In most instances, that will be either the Fourth Amendment's prohibition against unreasonable seizures of the person, or the Eighth Amendment's ban on cruel and unusual punishments, . . . . The validity of the claim must then be judged by reference to the specific constitutional standard which governs that right, rather than to some generalized 'excessive force' standard." (Id. at p. 394.) The court held "that all claims that law enforcement officers have used excessive force . . . 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, rather than under . . . the more generalized notion of 'substantive due process,'. . ." (Id. at p. 395.) The U.S. Supreme Court addressed the issue of excessive force and concluded that such is to be analyzed under an objective standard of reasonableness: "The reasonableness inquiry in excessive force cases is an objective one, the question being whether the officers' actions are objectively reasonable in light of the facts and circumstances confronting them, without regard to the officers' underlying intent or motivation and without the 20/20 vision of hindsight." A balancing test is used in determining "reasonableness". Id. It considers "the nature and quality of the intrusion on the individual's Fourth Amendment interests against the countervailing governmental interests at stake." Id. "Because the test of reasonableness is not capable of precise definition or mechanical application, its proper application 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.