Zorn v. Linton · ¶35

The Court's attempts to distinguish Amnesty America are mistaken. It first claims that Amnesty America differs from this case because the officers there did not give “any warning” to the protestors, while Zorn “repeatedly warned Linton” here. Ante, at 573. That distinction misrepresents both cases. Amnesty America, in fact, did involve warnings: It observed that the “police purportedly employed” the pain-compliance techniques “only after they were unsuccessful in verbally convincing protestors to move.” 361 F. 3d, at 119. By comparison, in this case, construing the evidence in favor of Linton (as is required), Zorn “did not issue any `clear request or command' ” before applying a rear wristlock and began asking her to stand only after he had initiated the wristlock. App. 46; see ECF Doc. 74–3, p. 2 (Linton “was not given warning before [Zorn] initiated the use of pain compliance”).…

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