Hello, this is RJ Deakin, reading the Supreme Court of the United States opinion syllabus in Jacob P. Zorn versus Sheila M. Linton. Um petition for a writ of sortiari to the United States Court of Appeals for the Second Circuit. Decided March 23rd, 2026. This one is a percurium opinion, and it's actually the opinion, not a syllabus. So we're just going to go ahead and read the whole thing. On the governor's inauguration day in Vermont, protesters staged a sit-in at the state capitol. When the Capitol closed for the day, police officers told them they would be arrested for trespassing. They refused to leave. As officers removed the protesters one by one, Sergeant Jacob Zorn asked Sheila Linton to stand up and warned her that he would eventually have to use force to remove her. She refused to stand. Zorn took Linton's arm, put it behind her back, placed pressure on her wrist, and lifted her to her feet. Linton sued Zorn for using excessive force, claiming that the arrest left her with arm injuries and psychological disorders. The Second Circuit held that Zorn was not entitled to qualified immunity. We reverse. On January 8th, 2015, Vermont hosted the inauguration for Governor Peter Schulmelin in the Capitol. About 200 protesters attended, and some of them staged a sit-in to demand universal health care. Sheila Linton joined them. She planned to refuse to leave and anticipated being forcibly removed. Quote from her deposition, June 3rd says, that's the point of the sit-in part of the protest. And there was a footnote there, that uh case uh footnote says, Because this case comes here on Zoran's motion for summary judgment, we view the facts in light in the light most favorable to the non-moving party, Linton. Uh and that's uh citing City and County San Francisco versus Sheehan from 2015. When the Capitol closed to the public for the night, 29 protesters remained in the legislative chamber, sitting on the floor with their arms linked. At that point, police officers explained that they would arrest the protesters for trespass if they did not leave. The officers dealt with them one at a time. Some stood up and were escorted out of the chamber without force, but others refused to stand and had to be lifted to their feet or dragged out. After removing more than a dozen protesters, the officers turned to Linton. Sergeant Jacob Zorn crouched down to speak with her, but she remained seated with her arms interlocked with those of her fellow protesters. As Linton passively resisted, Zorn unlinked her arm from another protester's, put it behind her back in a rear wrist lock, and twisted her arm. Linton exclaimed, ow, ow, ow, while Zorn repeatedly implored her to please stand up. And there was a footnote there saying a rear wrist lock is a technique that officers use to gain control over a resistant person by gripping their wrist, placing it behind their back, and bending it backwards. See U.S. Department of Justice, use of force by police overview and national and local data from October 1999, summarizing data showing that when the suspects use slight resistance, most incidents involved officer use of verbal commands, handcuffing, or wrist and arm locks. Zorn told her that he would ask one more time and then would use more pain compliance. Linton refused, so Zorn placed pressure on her wrist and lifted her up by her underarm. Linton yelled as she stood up. Once on her feet, Linton continued to jerk her arms and fell back to the floor. Zorn asked her to stand up again, and when she did not, three officers picked her up by her arms and legs and carried her outside. Linton alleged resulting physical and psychological injuries, including post-traumatic stress disorder. Linton sued Zorn under Section 1979 and 42 USC Section 1983, claiming that Zorn violated her Fourth Amendment right against excessive use of force. The District Court granted summary judgment for Zorn after concluding that he was entitled to qualified immunity. The District Court reasoned that it was not clearly established at the time of the encounter that in these circumstances, lifting Linton while putting pressure on her wrist violated the Fourth Amendment. The Second Circuit reversed. It held that its decision in Amnesty America versus West Hartford from 2004, Second Circuit, clearly established that the gratuitous use of a rear wrist lock on a protester passively resisting arrest constitutes excessive force. And that was uh 2025 uh decision, 135 F4th, 19 and 35. It remained uh remanded for a jury trial against Zorn. Judge Cobranes dissented. The case before us is not an exceptional case, Judge Cabrain's reason, but a routine arrest and removal. Government officials enjoy qualified immunity from suit under Section 1983, unless their conduct violates clearly established laws. That's uh Rivas Villigas versus Cortes Luna from 2021. A right is clearly established when it is sufficiently clear that every reasonable official would have understood what he is doing violates that right. A right is not clearly established if existing precedent does not place the constitutional question beyond debate. To find that a right is clearly established, courts generally need to identify a case where an officer acting under similar circumstances was held to have violated the Constitution. That's uh Escondido versus Ammons from uh 2019 Procurium opinion. Um The relevant precedent must define the right with a high degree of specificity, so that every reasonable official would interpret it to establish the particular rule the plaintiff seeks to apply. That's uh District of Columbia versus Wesby from 2018. Principles stated generally, such as that an officer may not use unreasonable and excessive force, do not suffice. That's Casella versus Hughes from 2018. In short, officers receive qualified immunity unless they could have read the relevant precedent beforehand and known that it proscribed their specific conduct. That's City and County of San Francisco versus Sheehan from 2015. The Second Circuit contravened these principles. Amnesty America did not clearly establish that Zorn's specific conduct violated the Fourth Amendment. Uh, and there's a footnote there, which is we assume without deciding that controlling circuit precedent can clearly establish law for qualified immunity purposes, citing Rivas Villigas versus Cortes Luna from 2021. And again, amnesty is the Second Circuit's own case. Uh, whether any particular use of force violates the Fourth Amendment depends on the facts and circumstances of each particular case. That's Graham versus Connor from 1989, including whether the officer gave warnings before using force, uh, citing Barnes versus Felix from 2025. In Amnesty America, the court considered a wide range of allegations of excessive force. The officers rammed a protester's head into a wall, dragged another protester across the ground, and used rear wrist locks on two more protesters to lift them up before throwing one of them back down to the ground. Nothing indicated that the officers gave the protesters any warning that they would use such force. Amnesty America did not hold that any of those actions violated the Fourth Amendment, let alone all of them. Instead, it remanded for a jury trial because while a reasonable jury could find that the officers gratuitously inflicted pain, it was also entirely possible that a reasonable jury would find that the police officer's use of force was objectively reasonable given the circumstances. Relevant here, Amnesty America even relied on a decision approving the practice of warning protesters and then using wrist locks to move them. And there's an internal citation, Forrester versus San Diego, which is California or CA9, um, 1994. Reasonable officials would not interpret Amnesty America to establish that using a routine wrist lock to move a resistant protester after warning her without more violates the Constitution. Uh citing Wesby and C. Sheehan, Zorn repeatedly warned Linton that he would have to use more force if she did not stand up, and when she did not do so, he used a wrist lock to bring Linton to her feet. Amnesty America never held that such conduct alone violated the Fourth Amendment. Um citing Emmons. If anything, it implied the opposite. The Second Circuit concluded otherwise by reading Amnesty America to establish the general principle that the gratuitous use of pain compliance techniques such as a rear wrist lock on a protester who is passively resisting arrest constitutes excessive force. But that principle, even assuming Amnesty America established it, lacks the high degree of specificity needed to make it clear to officers which actions violate the law. Citing Wesby there. It does not obviously resolve whether using a rear wrist lock to move a noncompliant protester after repeated warnings violates the Fourth Amendment, as it fails to specify which circumstances make use of force gratuitous. Because the Second Circuit failed to identify a case where an officer taking similar actions in similar circumstances was held to have violated the Constitution. Uh, citing Ammons, Zorn was entitled to qualified immunity. We grant his petition for a writ of certierari and reverse the judgment of the Second Circuit. It is so ordered. And again, that was a uh procurium opinion. Uh, so thanks for listening. If you'd like to get a hold of me, you can reach me at uh Rhodes Scholar80 at gmail.com, or you can stop by my new website at lokiesk.law, which is l o k iesq.law. Thanks.