Zorn v. Linton

In 2015, during the inauguration of Vermont’s governor, a group of protestors staged a sit-in at the state capitol, advocating for universal healthcare. When the building closed for the night, police warned the group they would be arrested for trespassing if they didn't leave.

In compliance with the police, most protestors left for the night. However, protestor Shela Linton did not follow these orders. After repeated verbal warnings, Sergeant Jacob Zorn took Linton's arm, placed it behind her back in a rear wristlock, applied pressure to her wrist, and lifted her to her feet, causing her to cry out in pain.

Linton alleged the encounter left her with arm injuries and post-traumatic stress disorder, and sued Zorn under Section 1983 for excessive force under the Fourth Amendment.

Rather than proceeding through full briefing and oral argument, the Supreme Court resolved this case through a per curiam opinion. This allowed the Court to issue an unsigned ruling without argument. Often, a per curiam opinion is reserved for cases the Court views as requiring only a summary correction of a lower court's error. 

The district court had granted Zorn qualified immunity, but the Second Circuit reversed, pointing to its own 2004 precedent, Amnesty America v. West Hartford, which it read as clearly establishing that a "gratuitous" rear wristlock on a passively resisting protester violates the Constitution. 

Without hearing any arguments, the Supreme Court made the case into a one-day affair, reversing the Second Circuit’s ruling on March 23rd 2026.

Zorn argued that qualified immunity shields officers unless a prior case put the unlawfulness of their specific conduct "beyond debate," and that Amnesty America (a case involving a range of force, some far more aggressive than a warned, routine wristlock) never held that this precise scenario was unconstitutional.

Linton argued that the Second Circuit had correctly applied precedent from within its own circuit, that lifting a peaceful, seated protester by force after she had merely declined to stand was exactly the kind of "gratuitous" force Amnesty America condemned, and that the Court's summary reversal was an extraordinary and unwarranted step to take in her case.

The per curiam majority sided with Zorn, holding that Amnesty America lacked the "high degree of specificity" needed to clearly establish that this particular technique, used after repeated warnings against a noncompliant protester, was unlawful. Because the Second Circuit couldn't point to a case with sufficiently similar facts finding a constitutional violation, qualified immunity applied. 

Justice Sotomayor, joined by Justices Kagan and Jackson, dissented, arguing the Second Circuit's conclusion wasn't so clearly wrong as to justify the "extraordinary remedy" of a summary reversal without argument. The case is a reminder of how demanding the "clearly established law" standard has become in qualified immunity cases and of the Court's continued willingness to summarily reverse lower courts that rule against police officers, even without full briefing, while reserving that same summary treatment far less often for plaintiffs alleging civil rights violations.