plainly incompetent or those who knowingly violate the law.” Malley v. Briggs, 475 U.S. 335, 341, 106 S.Ct. 1092, 89 L.Ed.2d 271 (1986). A duty to render medical care is generally thought of as arising under the Due Process Clause or the Eighth Amendment. See, e.g., DeShaney v. Winnebago County Dep’t of Soc. Servs., 489 U.S. 189, 200, 109 S.Ct. 998, 103 L.Ed.2d 249 (1989); see also Salazar v. City of Chicago, 940 F.2d 233, 241 (7th Cir.1991) (employing the “deliberate indifference” standard in assessing the actions of paramedics and police officers). At least one court, however, has recognized that alleged failures to provide medical care during a seizure or arrest are cognizable under the Fourth Amendment. See Estate of Phillips v. City of Milwaukee, 123 F.3d 586, 596 (7th Cir.1997) (<HOLDING>); cf. Boone v. Spurgess, 385 F.3d 923, 933-34
holding that an initially reasonable seizure can become an unreasonable seizure that violates the fourth amendment when officers refuse to return seized property holding that a warrant issued by a neutral magistrate creates presumption that officers belief in probable cause was objectively reasonable holding that parents claims of outrage and negligent handling of a body were not subject to the medical malpractice statutes because hospital personnel did not engage in any medical skill or judgment in the disposition of the childs remains holding that officers were objectively reasonable in handling plaintiffs medical situation during seizure holding that hcv constitutes an objectively serious medical condition