This case arose from a sit-in protest at the Vermont State Capitol during a gubernatorial inauguration. Approximately 200 protesters staged a sit-in to demand universal healthcare and refused to leave when the capitol closed. Police officers began removing them one by one. Sergeant Jacob Zorn approached Shela Linton, who was seated and interlocking her arms with other protesters. After she refused to stand despite verbal warnings, Zorn placed her arm behind her back in a rear wristlock, twisted her arm, and lifted her to her feet. Linton sued Zorn under 42 U.S.C. § 1983, alleging excessive force in violation of the Fourth Amendment. The District Court granted summary judgment for Zorn, but the Second Circuit reversed, holding that a prior Second Circuit decision clearly established that using a rear wristlock on a passively resisting protester constituted excessive force. The Second Circuit remanded the case for a jury trial.
The Court, in a Per Curiam opinion, focused entirely on the second prong of the qualified immunity analysis: whether the law was clearly established. The Court reiterated that a right is clearly established only if existing precedent places the constitutional question beyond debate and defines the right with a high degree of specificity. The Court found that the Second Circuit erred in relying on Amnesty America v. West Hartford. The Court distinguished that case, noting that Amnesty America involved a wide range of aggressive conduct, including ramming heads into walls and dragging protesters, without any warnings. In contrast, Zorn repeatedly warned Linton before using the wristlock. The Court held that Amnesty America did not hold that using a wristlock alone violated the Fourth Amendment, nor did it clearly establish that the specific conduct here was unlawful. Because no case held that an officer acting under similar circumstances—using a wristlock on a passive resister after warnings—violated the Constitution, Zorn was entitled to immunity.
The decision reinforces the high bar for overcoming qualified immunity in excessive force cases involving protesters. It signals that officers will likely be protected from liability unless there is a prior case with nearly identical facts that explicitly held similar conduct unconstitutional. The case is remanded to the lower courts, but the reversal effectively ends Linton's ability to proceed against Zorn at the summary judgment stage. It leaves open the question of whether the force was actually excessive under the Fourth Amendment, as the Court did not reach the first prong of the qualified immunity analysis.