If no Fourth Amendment seizure took place, would Plaintiffs' claims be considered under the Fourteenth Amendment?

MultiRegion, United States of America

The following excerpt is from Toscano v. City of Fresno, Case No. 1:13-cv-01987-SAB (E.D. Cal. 2015):

Graham v. Connor, 490 U.S. 386, 395 (1989). However, if no Fourth Amendment seizure took place, then Plaintiffs' claims would be considered under the Fourteenth Amendment.

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