Does the seizure under the Fourteenth Amendment constitute an unlawful seizure?

To the extent Plaintiffs state a seizure occurred under the Fourteenth Amendment, this claim is dismissed. See Graham v. Connor, 490 U.S. 386 394-95 (1989) ("all claims that law enforcement officers have used excessive forcedeadly or notin 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 a "substantive due process" approach. Because the Fourth Amendment provides an explicit textual source of constitutional protection against this sort of physically intrusive governmental conduct, that Amendment, not the more generalized notion of "substantive due process," must be the guide for analyzing these claims").

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