With no explanation, chose the best option from "A", "B", "C" or "D". Graham, this court concludes that defendants have read [Graham ] too broadly. The Supreme Court in Graham did not hold that all prearrest excessive force claims are to be analyzed exclusively under the Fourth Amendment. ... As the plaintiffs [sic] claim is not encompassed by some other enumerated right, plaintiffs' allegations are sufficient to state a substantive due process claim under the Fourteenth Amendment.”). Further, those cases which hold that excessive force claims by pretrial detainees, to whom the Eighth Amendment does not apply, are to be analyzed under substantive due process, are consistent with the idea that Graham only requires a Fourth Amendment claim when that is the constitutional right truly implicated. See Brogsdale v. Barry, 926 F.2d 1184, 1187 (D.C.Cir.1991) (<HOLDING>); Fields v. City of South Houston, 922 F.2d

A: recognizing that plaintiff can bring action under due process clause of state constitution
B: holding that pretrial detainees can bring substantive due process claim
C: recognizing  1983 substantive due process claim
D: recognizing pretrial detainees constitutional right to be from excessive force
B.