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In a recent per curium decision, the United States Supreme Court in Zorn v. Linton affirmed summary judgment for a law enforcement officer under the doctrine of qualified immunity—a legal protection that shields government employees and law enforcement from being sued unless they violate a clearly-established law. See 607 U.S. ___ , 146 S. Ct. 926 (2026).
The plaintiff, Shela Linton, joined a sit-in protest at the Vermont Statehouse in 2015. When the building closed, police told protesters they had to leave or face arrest. Linton refused to move. Sergeant Jacob Zorn warned Linton several times that he would have to use force if she did not stand up. When she still refused, the officer used a "rear wristlock"—a technique that applies pressure to the wrist to cause pain—to bring her to her feet. Linton later sued Sergeant Zorn, claiming the force was excessive under the Fourth Amendment.
The Supreme Court ruled in favor of Sergeant Zorn. The Court explained that for an officer to lose immunity, there generally needs to be a previous case “where an officer acting under similar circumstances … was held to have violated the Constitution.” Id., citing Escondido v. Emmons, 586 U.S. 38, 43 (2019). “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.” Zorn, 146 S. Ct. at 930 (internal citations and quotations omitted). The Court held that previous cases did not clearly state that using a wristlock on a passive protester after giving multiple warnings was a violation of the Fourth Amendment. The Court reasoned that, because there was not a rule "beyond debate" against Zorn's specific actions at the time, he was entitled to qualified immunity for his action of applying the wristlock.
For government entities, including those in local government and law enforcement, this case reinforces a high bar for lawsuits. It highlights that a law must be "clearly established" with precision before an official may be held liable for their actions taken while on the job.
To read the Court’s ruling in detail, and to read the dissenting opinion, please visit www.supremecourt.gov/opinions/25pdf/24-993_10n2.pdf.
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