Zorn v. Linton · ¶36

It is true that, after initiating the wristlock, Zorn warned Linton that he would use “ `more pain compliance' ” if she did not stand up, App. 48, whereas the Amnesty America opinion does not specify whether similar warnings were given after the initiation of the wristlocks. If that is the difference on which the majority relies, the majority is essentially requiring Linton to find a factually identical case, a requirement that this Court has repeatedly rejected. See, e. g., An derson, 483 U. S., at 640 (“This is not to say that an official action is protected by qualified immunity unless the very action in question has previously been held unlawful”); Hope, 536 U. S., at 741 (explaining that “ `fundamentally similar' ” cases can be helpful but are not necessary).

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