Zorn v. Linton · ¶19

Sergeant Jacob Zorn used a “ `pain compliance technique' ” called a rear wristlock on Shela Linton, a nonviolent protestor who was peacefully demonstrating at a sit-in in the Vermont capitol. 135 F. 4th 19, 24–25 (CA2 2025). The Second Circuit held that Zorn was not entitled to qualified immunity on Linton's Fourth Amendment excessive force claim, at least at the summary judgment stage, because prior Circuit precedent had clearly established that using a rear wristlock against a nonviolent protestor would violate the protestor's constitutional rights. That decision was not erroneous, and certainly not so clearly erroneous as to warrant the “extraordinary remedy of a summary reversal.” Major League Baseball Players Assn. v. Garvey, 532 U. S. 504, 512– 513 (2001) (Stevens, J., dissenting). I respectfully dissent.

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