Zorn v. Linton · ¶32

In addition to the long-established principle that officers may use only the “amount of force that is necessary in a particular situation,” Graham, 490 U. S., at 397, the Second Circuit's prior case, Amnesty America v. West Hartford, 361 F. 3d 113 (2004), “clearly establish[ed] 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. In that case, officers used multiple forms of force to arrest anti-abortion protestors who had chained themselves together in front of a women's center. Amnesty America, 361 F. 3d, at 118. The plaintiffs alleged that the officers had used excessive force to remove them, including by using a rear wristlock and other pain compliance techniques. Ibid. Two plaintiffs in that case were treated much like Linton was: Officers “lift[ed] and…

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