with our inteipretation of Graham. See Albright v. Oliver, - U.S. -, -, 114 S.Ct. 807, 813, 127 L.Ed.2d 114 (1994) (noting that Graham only bars substantive due process claims when a particular amendment provides an explicit textual source of constitutional protection). 12 . A number of federal courts have interpreted Graham in this manner. See, e.g., Sinaloa Lake Owners Ass’n v. City of Simi Valley, 882 F.2d 1398, 1409 n. 13 (9th Cir.1989) (Kozinski, J.) (applying substantive due process test and holding that Graham only dictated use of the fourth amendment test when "the plaintiff alleges governmental abuse not covered by another constitutional standard”), cert. denied, 494 U.S. 1016, 110 S.Ct. 1317, 108 L.Ed.2d 493 (1990); Pleasant v. Zamieski, 895 F.2d 272, 276 n. 2 (6th Cir.) (<HOLDING>), cert. denied, 498 U.S. 851, 111 S.Ct. 144,
holding that all claims that law enforcement officers have used excessive force  deadly or not  in 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 holding in a deadly force case that despite the broad phrasing of graham  presumably this imperative would preserve fourteenth amendment substantive due process analysis for those instances in which a free citizen is denied his or her constitutional right  through means other than a law enforcement officials arrest investigatoiy stop or other seizure holding that there is no substantive due process right under the fourteenth amendment to be free from malicious prosecution holding that all claims that law enforcement officers have used excessive force deadly or not  in 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 holding excessive force in public school context is a violation of substantive due process guaranteed by the fourteenth amendment