In the case of Escondido v. Emmons, the U.S. Supreme Court ruled in favor of two police officers from Escondido, California who were accused of using excessive force during an arrest. The plaintiff, Marty Emmons, claimed his Fourth Amendment rights had been violated when he was forcefully arrested without provocation after exiting his apartment. However, the court found that the officers involved were entitled to qualified immunity as there was no clear violation of any constitutional right and because a reasonable officer could have believed that taking down a suspect in these circumstances was lawful given previous precedents set by other courts on similar cases.

In the dissenting opinion for Escondido v. Emmons, Justice Sonia Sotomayor criticized the majority's decision to grant qualified immunity to police officers who used excessive force during an arrest. She argued that the court had overstepped its authority by re-framing the question presented and deciding on a ground not briefed or argued before them. The case was about whether clearly established law prohibits a police officer from using gratuitous force against a non-resisting, compliant person during an arrest; however, she noted that this issue was never addressed in their ruling. Instead, they focused on whether one specific officer could be held liable when it wasn't clear he personally applied physical force against Emmons - something neither party disputed nor asked them to resolve. Sotomayor expressed concern that such decisions undermine public trust in judicial processes and erode Fourth Amendment protections.