Zorn v. Linton

AI-Generated Summary

During Vermont Governor Peter Shumlin's inauguration on January 8, 2015, about 200 protesters attended, including Shela Linton, who participated in a sit-in demanding universal healthcare and anticipated forcible removal.
When the capitol closed, 29 protesters remained seated with arms linked; police warned of trespass arrests and removed them one by one—some complied voluntarily, others required lifting or dragging.
Sergeant Jacob Zorn approached Linton, who refused to stand; he unlinked her arm, applied a rear wristlock (twisting her wrist behind her back), warned her repeatedly of increased force, applied pressure to lift her, after which she yelled in pain, collapsed, and was carried out by officers.
Linton alleged permanent wrist/shoulder injuries and psychological disorders (e.g., PTSD).
Procedural History: Linton sued Zorn under 42 U.S.C. §1983 for excessive Fourth Amendment force. District Court (D. Vt.) granted summary judgment for Zorn on qualified immunity. Second Circuit reversed (135 F.4th 19 (2025)), holding Amnesty America v. West Hartford (361 F.3d 113 (2004)) clearly established excessive force; remanded for jury trial. Supreme Court granted certiorari.

Whether Zorn was entitled to qualified immunity on Linton's Fourth Amendment excessive force claim during her arrest for trespass.
Involves constitutional interpretation (Fourth Amendment right against unreasonable seizures) under the qualified immunity framework (42 U.S.C. §1983).
Main Arguments: Zorn/Petitioner: No clearly established law prohibited warned use of routine rear wristlock on passively resisting protester. Linton/Respondent & Second Circuit: Amnesty America clearly established that gratuitous rear wristlocks on passive protesters constitute excessive force.

Author & Type: Per Curiam (majority opinion).
Holding: Zorn was entitled to qualified immunity because prior precedent (Amnesty America) did not clearly establish that his specific conduct—repeatedly warning and then using a rear wristlock to lift a passively resisting protester—violated the Fourth Amendment.
Legal Reasoning: Qualified immunity applies unless conduct violates clearly established law "beyond debate," defined with "high degree of specificity" via precedent involving similar circumstances (Rivas-Villegas v. Cortesluna, 595 U.S. 1 (2021); District of Columbia v. Wesby, 583 U.S. 48 (2018); Kisela v. Hughes, 584 U.S. 100 (2018)); general principles (e.g., no excessive force) insufficient (Graham v. Connor, 490 U.S. 386 (1989)). Amnesty America involved varied force allegations (e.g., head-ramming, dragging), remanded without holding violations occurred, cited approving precedent for warned wristlocks (Forster v. San Diego, 25 F.3d 804 (CA9 1994)), and did not address warnings or Zorn's narrow actions, failing to put reasonable officers on notice (City and County of San Francisco v. Sheehan, 575 U.S. 600 (2015)).
Disposition: Petition for certiorari granted; judgment of Second Circuit reversed.

Justice Sotomayor (joined by Justices Kagan and Jackson): Would deny summary reversal, as Second Circuit correctly denied qualified immunity; viewing facts favorably to Linton (Tolan v. Cotton, 572 U.S. 650 (2014)), Zorn's unwarned initiation of rear wristlock on nonviolent, passively resisting protester (low-threat trespass, no active resistance, permanent injuries) violated clearly established Fourth Amendment law (Graham; Kingsley v. Hendrickson, 576 U.S. 389 (2015)); Amnesty America involved fundamentally similar warned-or-post-verbal wristlocks on passive protesters, creating jury question on excessiveness despite remand; criticizes majority's demand for "factually identical" precedent (Hope v. Pelzer, 536 U.S. 730 (2002)) and Court's "one-sided" summary reversals favoring immunity (Kisela, 584 U.S. at 120 (Sotomayor, J., dissenting)).

Reinforces stringent "clearly established" standard for denying qualified immunity, requiring precedent with high specificity on similar facts/circumstances rather than general principles or remands creating jury questions; assumes (without deciding) circuit precedent can suffice; protects officers using routine, warned pain-compliance (e.g., wristlocks) on passively resisting nonviolent protesters in low-threat settings like sit-ins; emphasizes totality-of-circumstances inquiry (Graham) including warnings (Barnes v. Felix, 605 U.S. 73 (2025)).

This summary was generated by AI and may contain inaccuracies. Refer to the official source document for the authoritative text.

Key terms: Sit-in Protest, Police Use of Force, Qualified Immunity