Massachusetts Supreme Judicial Court December 15, 1993 (Commonwealth v. Adams)

Lynch, J.

(concurring). The United States Supreme Court has held that excessive use of force claims against police officers are properly analyzed under the Fourth Amendment’s “objective reasonableness” standard rather than under a substantive due process standard.1 Graham v. Connor, 490 U.S. *572386, 388 (1989). Dean v. Worcester, 924 F.2d 364, 367 (1st Cir. 1991).