Zorn v. Linton

Questions presented

SCOTUS records

Question presented

Opinion summary

Etalia.ai summary of the majority opinion

A protester at the Vermont state capitol sued a state trooper under Section 1983, claiming the trooper used excessive force when he applied a rear wristlock, gave repeated warnings to stand up, and then lifted her to remove her from a sit-in. The lower court found qualified immunity, but the Second Circuit reversed, relying on its prior decision in Amnesty America. The Court reversed. It said qualified immunity protected the trooper because the Second Circuit did not identify a case clearly establishing that using a routine wristlock to move a resistant protester after warnings, without more, violates the Fourth Amendment. The Court emphasized that clearly established law must be defined with high specificity and that Amnesty America involved broader allegations and did not clearly resolve this situation.

Dissent summary

Etalia.ai summary of the dissenting opinions

Justice Sotomayor, joined by Justice Kagan and Justice Jackson, dissented. She argued that, taking the facts in the light most favorable to Linton, a jury could find that Zorn used excessive force against a nonviolent, passively resisting protester. She said Amnesty America clearly established that using a rear wristlock or similar pain compliance technique on such a protester can violate the Fourth Amendment, and that the majority wrongly demanded a factually identical case. She also said the Court’s summary reversal was unwarranted and would give officers too much protection from suit.