Supreme Court Rules Police Officer Entitled to Immunity in Excessive Force Case

In Zorn v. Linton, 607 U.S. ____ (2026), the U.S. Supreme Court held that a police officer was entitled to qualified immunity because the officer’s conduct had not violated a clearly established law. In its per curium opinion, the Court emphasized that the qualified immunity standard requires a “high degree of specificity” in prior precedent.

Facts of the Case

On the Governor’s inauguration day in Vermont, protesters staged a sit-in at the state capitol. When the capitol closed for the day, police officers told them that they would be arrested for trespassing. They refused to leave. As officers removed the protesters one by one, Sergeant Jacob Zorn asked Shela Linton to stand up and warned her that he would eventually have to use force to remove her. After she refused to stand, Zorn took Linton’s arm, put it behind her back, placed pressure on her wrist, and lifted her to her feet.

Linton sued Zorn under 42 U.S.C. §1983, claiming that Zorn violated her Fourth Amendment right against excessive use of force. The District Court granted summary judgment for Zorn after concluding that he was entitled to qualified immunity. The District Court reasoned that it was not clearly established at the time of the encounter that, in these circumstances, lifting Linton while putting pressure on her wrist violated the Fourth Amendment.

The Second Circuit Court of Appeals reversed. Itheld that its decision in Amnesty America v. West Hartford, 361 F.3d 113 (2004), clearly established that the “gratuitous” use of a rear wristlock on a protester passively resisting arrest constitutes excessive force.

Supreme Court’s Decision

In a per curium opinion, the Supreme Court reversed, holding that Zorn was entitled to qualified immunity because the officer’s conduct had not violated clearly established law.

As the Court explained, Government officials enjoy qualified immunity from suit under §1983 unless their conduct violates clearly established law. A right is clearly established when it is “sufficiently clear that every reasonable official would have understood that what he is doing violates that right.” Conversely, a right is not clearly established if existing precedent does not place the constitutional question “beyond debate.”

In this case, the Court found that the Second Circuit erred becauseAmnesty Americadid not clearly establish that his specific conduct violated the Fourth Amendment. “Reasonable officials would not ‘interpret [Amnesty America] to establish’ that using a routine wristlock to move a resistant protester after warning her, without more, violates the Constitution,” the Court wrote.

The Supreme Court further found that the Second Circuit erroneously read Amnesty America to establish the general principle “that the gratuitous use of pain compliance techniques—such as a rear-wristlock—on a protestor who is passively resisting arrest constitutes excessive force.” According to the Court, even assuming Amnesty America established that principle, it lacks the “high degree of specificity” needed to make it “clear” to officers which actions violate the law.

Finally, the Supreme Court concluded that the Second Circuit failed to identify a case where an officer taking similar actions in similar circumstances was held to have violated the Constitution. Thus, Zorn was entitled to qualified immunity.

Dissent

Justice Sonia Sotomayor wrote a dissenting opinion, which was joined by Justices Elena Kagan and Ketanji Brown-Jackson. The dissenters agreed with the Second Circuit, arguing that the district court should have denied summary judgment for Zorn because a jury could find that his use of force was excessive and violated Linton’s clearly established rights.

“The Second Circuit held that Zorn was not entitled to qualified immunity on Linton’s Fourth Amendment excessive force claim, at least at the summary judgment stage, because prior Circuit precedent had clearly established that using a rear wristlock against a nonviolent protestor would violate the protestor’s constitutional rights,” Justice Sotomayor wrote. “That decision was not erroneous, and certainly not so clearly erroneous as to warrant the ‘extraordinary remedy of a summary reversal.’”