Does the arrest, investigatory stop, or other seizure of a free citizen under the Fourth Amendment apply to substantive due process?

MultiRegion, United States of America

The following excerpt is from Wilburn v. Bratcher, No. 2:15-cv-00699 TLN GGH (E.D. Cal. 2016):

an arrest, investigatory stop, or other seizure of a free citizen should be analyzed under the Fourth Amendment rather than under substantive due process. Graham v. Connor, 490 U.S. 386, 395 (1989).

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