Zorn v. Linton · ¶16

The Second Circuit concluded otherwise by reading Am nesty America to establish the general principle “that the gratuitous use of pain compliance techniques—such as a rearwristlock—on a protestor who is passively resisting arrest constitutes excessive force.” 135 F. 4th, at 35 (case below). But that principle, even assuming Amnesty America established it, lacks the “high degree of specifcity” needed to make it “clear” to officers which actions violate the law. Wesby, 583 U. S., at 63 (internal quotation marks omitted). It does not “obviously resolve” whether using a rear wrist- lock to move a noncompliant protester after repeated warnings violates the Fourth Amendment, id., at 64, as it fails to specify which circumstances make the use of force “gratuitous.”

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