Docket 25-297
Zorn v. Linton
DecidedMar 23, 2026
6-3decision
Source: CourtListener.
Court grants qualified immunity to officer who used wristlock on nonviolent sit-in protester
What it does
The Court reversed the Second Circuit and held that Sergeant Zorn was entitled to qualified immunity — a legal doctrine that shields government officials from lawsuits unless they violated a "clearly established" legal right. The Court found that no prior case had specifically held, with enough factual similarity, that using a wristlock to lift a noncompliant protester after repeated warnings violates the Fourth Amendment. Because the law was not clearly established with sufficient specificity, Zorn cannot be sued for the conduct.
Who benefits
Police officers who use physical force techniques to remove nonviolent, passively resisting protesters during lawful arrests, and who face civil rights lawsuits under federal law (42 U.S.C. §1983).
Who is affected
People who participate in sit-in protests, are physically removed by police using pain-compliance techniques, and seek to sue officers for excessive force under the Fourth Amendment.
Practical impact
Police officers who use standard physical removal techniques — such as wristlocks — to remove nonviolent sit-in protesters after issuing warnings will face a higher bar for civil rights lawsuits, as plaintiffs must now identify a prior case with closely matching facts to overcome qualified immunity. People injured during protest removals who seek to hold individual officers accountable in court will find it harder to survive the early stages of a lawsuit. The ruling does not decide whether Zorn's conduct was actually constitutional — only that the law was not clear enough at the time to expose him to personal liability.
Majority reasoning
The Court held that qualified immunity applies unless prior precedent placed the unconstitutionality of an officer's specific conduct "beyond debate," meaning a reasonable officer could have read existing case law and known their exact actions were unlawful. The majority found that the Second Circuit's 2004 decision in Amnesty America v. West Hartford did not meet that bar, because that case involved a wide range of aggressive conduct, never actually held any specific action unconstitutional, and even cited a case approving the use of wristlocks after warnings. The majority reasoned that Amnesty America at most established a general principle — that "gratuitous" use of pain techniques on passive protesters can be excessive — but general principles are not specific enough to put officers on notice. Because Zorn gave repeated warnings before applying the wristlock, and no prior case had specifically held that such a sequence of events violated the Fourth Amendment, the law was not clearly established. The Second Circuit therefore erred by denying Zorn qualified immunity.
Dissent reasoning
The dissent argued that the Second Circuit correctly denied qualified immunity and that this case did not warrant the extraordinary step of a summary reversal by the Supreme Court. Justice Sotomayor contended that Amnesty America did clearly establish the relevant rule — that using a rear wristlock as a pain-compliance technique against a nonviolent, passively resisting protester can constitute excessive force — with enough specificity to put Zorn on notice. The dissent also challenged the majority's key factual distinction: the majority said Zorn gave warnings before using force, but the dissent pointed out that, viewing the evidence in Linton's favor as required at the summary judgment stage, Zorn applied the wristlock before issuing any clear command, and only told her to stand up after the pain had already begun. The dissent further argued that the majority was effectively requiring a factually identical prior case to establish the law clearly — a standard the Supreme Court has repeatedly rejected. Finally, the dissent expressed concern that the Court's pattern of summarily reversing decisions that deny officers qualified immunity, while rarely intervening when courts wrongly grant it, turns qualified immunity into an absolute shield that undermines the Fourth Amendment's guarantee that officers may only use force that is necessary under the circumstances.
Constitutional question
Did a Second Circuit precedent clearly establish that a police officer violates the Fourth Amendment's prohibition on excessive force by using a rear wristlock to remove a nonviolent, passively resisting protester from a sit-in after giving repeated warnings?