Zorn v. Linton

607 U. S. 568 (2026) · 3/23/26

Because the Second Circuit failed to identify a case where an officer using a routine wristlock on a protester after issuing a verbal warning, without more, was held to have violated the Constitution, Sergeant Jacob Zorn was entitled to qualified immunity; the Second Circuit’s contrary conclusion was erroneous.

Shela Linton joined a protest at the Vermont state capitol building to demand universal healthcare, and was among the protesters who refused to leave when the capitol closed. As the protesters sat on the foor of the legislative chamber with their arms linked, police officers explained that they would arrest the protesters for trespass if they did not leave. After removing more than a dozen protesters one by one, the officers turned to Linton. Sergeant Jacob Zorn crouched down to speak with her, but she remained seated with her arms interlocked with those of her fellow protesters. As Linton…

Held: Because the Second Circuit failed to identify a case where an officer using a routine wristlock on a protester after issuing a verbal warning, without more, was held to have violated the Constitution, Zorn was entitled to qualified immunity. Government officials enjoy qualified immunity from suit under § 1983 unless their conduct violates clearly es