Zorn v. Linton

P R E L I M I N A R Y P R I N T
Volume 607 U. S. Part 2
Pages 568–582
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T H E S U P R E M E C O U R T
March 23, 2026
REBECCA A. WOMELDORF
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568 OCTOBER
TERM, 2025
Syllabus
ZORN v. LINTON
certiorari
to the united states court of appeals for
the second circuit
No. 25–297. Decided March 23, 2026
Shela Linton joined a protest at the Vermont state capitol building to
demand universal healthcare, and was among the protesters who re-
fused to leave when the capitol closed. As the protesters sat on the
foor of the legislative chamber with their arms linked, police offcers
explained that they would arrest the protesters for trespass if they did
not leave. After removing more than a dozen protesters one by one,
the offcers 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 un-
linked her arm from another protester's, put it behind her back in a
rear wristlock, and twisted her arm. Zorn repeatedly implored her to
“please stand up.” App. to Pet. for Cert. 47–48. After Linton refused,
Zorn told her that he would ask “one more time” and then would use
more pain compliance. Id., at 48. Linton again refused, so Zorn placed
pressure on her wrist and lifted Linton up by her underarm. Once on
her feet, Linton continued to jerk her arms and fell back to the foor.
Zorn asked her to stand up again, and when she did not, three offcers
picked her up by her arms and legs and carried her outside. Linton
alleged resulting physical and psychological injuries, and sued Zorn
under Rev. Stat. § 1979, 42 U. S. C. § 1983, claiming that Zorn violated
her Fourth Amendment right against excessive use of force. The Dis-
trict Court granted summary judgment for Zorn after concluding that
he was entitled to qualifed 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 v. West Hartford, 361 F. 3d
113, clearly established that the use of a rear wristlock on a protester
passively resisting arrest constitutes excessive force, and remanded for
a jury trial against Zorn.
Held: Because the Second Circuit failed to identify a case where an offcer
using a routine wristlock on a protester after issuing a verbal warning,
without more, was held to have violated the Constitution, Zorn was
entitled to qualifed immunity. Government offcials enjoy qualifed im-
munity from suit under § 1983 unless their conduct violates clearly es-

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Cite
as: 607 U. S. 568 (2026)
569
Per Curiam
tablished law. Rivas-Villegas v. Cortesluna, 595 U. S. 1, 5 (per cu-
r
iam). To fnd that a right is clearly established, courts generally
“need to identify a case where an offcer acting under similar circum-
stances . . . was held to have violated” the Constitution. Escondido v.
Emmons, 586 U. S. 38, 43 (per curiam) (internal quotation marks omit-
ted). The relevant precedent must defne the right with a “high degree
of specifcity,” so that “every reasonable offcial would interpret it to
establish the particular rule the plaintiff seeks to apply.” District of
Columbia v. Wesby, 583 U. S. 48, 63 (internal quotation marks omitted).
Amnesty America—the precedent relied upon by the Second Circuit—
did not clearly establish that Zorn's specifc conduct violated the Fourth
Amendment. Amnesty America involved a wide range of allegations
of excessive force by police with no indication that the offcers gave the
protesters any warning that they would use such force. 361 F. 3d, at
123. Reasonable offcials would not “interpret [Amnesty America] to
establish” that using a routine wristlock to move a resistant protester
after warning her, without more, violates the Constitution. Wesby, 583
U. S., at 63. The Second Circuit concluded otherwise by reading Am-
nesty America to establish the general principle “that the gratuitous
use of pain compliance techniques—such as a rear-wristlock—on a pro-
testor who is passively resisting arrest constitutes excessive force.”
135 F. 4th 19, 35. But that principle, even assuming Amnesty America
established it, lacks the “high degree of specifcity” needed to make it
“clear” to offcers which actions violate the law. Wesby, 583 U. S., at
63 (internal quotation marks omitted). It does not “obviously resolve”
whether using a rear wristlock to move a noncompliant protester after
repeated warnings violates the Fourth Amendment, id., at 64, as it fails
to specify which circumstances make the use of force “gratuitous.” Ac-
cordingly, Zorn was entitled to qualifed immunity.
135 F. 4th 19, certiorari granted, judgment reversed.
Per Curiam.
On the Governor's inauguration day in Vermont, protest-
ers staged a sit-in at the state capitol. When the capitol
closed for the day, police offcers told them that they would
be arrested for trespassing. They refused to leave. As of-
fcers removed the protesters one by one, Sergeant Jacob
Zorn asked Shela Linton to stand up and warned her that he
would eventually have to use force to remove her. She re-
fused to stand. Zorn took Linton's arm, put it behind her
back, placed pressure on her wrist, and lifted her to her feet.

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570 ZORN
v. LINTON
Per Curiam
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 quali-
fed immunity. We reverse.
I
On January 8, 2015, Vermont hosted the inauguration for
Governor Peter Shumlin in the capitol.
1
About 200 protest-
ers attended, and some of them staged a sit-in to demand
universa l hea lthcare. Shela Linton joined them. She
planned to refuse to leave and anticipated being forcibly re-
moved. “That's the point of the sit-in part of the protest,”
she later explained. Deposition of S. Linton in No. 5:18–cv–
5 (D Vt., June 3, 2022), ECF Doc. 74–4, p. 127.
When the capitol closed to the public for the night, 29 pro-
testers remained in the legislative chamber, sitting on the
foor with their arms linked. At that point, police offcers
explained that they would arrest the protesters for trespass
if they did not leave. The offcers 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 offcers
turned to Linton. Sergeant Jacob Zorn crouched down to
speak with her, but she remained seated with her arms inter-
locked with those of her fellow protesters. As Linton pas-
sively resisted, Zorn unlinked her arm from another protest-
er's, put it behind her back in a rear wristlock, and twisted
her arm.
2
Linton exclaimed “ `ow, ow, ow,' ” while Zorn re-
1
Because this case comes here on Zorn's motion for summary judgment,
we view the facts in the light most favorable to the nonmoving party,
Linton. City and County of San Francisco v. Sheehan, 575 U. S. 600,
603 (2015).
2
A rear wristlock is a technique that offcers use to gain control over a
resistant person by gripping his wrist, placing it behind his back,
and bending it backward. See Dept. of Justice, Use of Force by Police:
Overview of National and Local Data 49 (Oct. 1999) (summarizing data

Cite
as: 607 U. S. 568 (2026)
571
Per Curiam
peatedly implored her to “ `please stand up.' ” App. to Pet.
for
Cert. 47–48. After Linton responded, “ `I will not stand
up,' ” Zorn told her that he would ask “ `one more time' ” and
then would use more pain compliance. Id., at 48. 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 foor. Zorn asked her to stand up again, and when
she did not, three offcers 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 Rev. Stat. § 1979, 42 U. S. C.
§ 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 qualifed immunity. The District Court
reasoned that it was not clearly established at the time of the
encounter that, in these circumstances, lifting Linton while
putti ng pressure on her wr ist v i olated the Four th
Amendment.
The Second Circuit reversed. It held that its decision in
Amnesty America v. West Hartford, 361 F. 3d 113 (2004),
clearly established that the “gratuitous” use of a rear wrist-
lock on a protester passively resisting arrest constitutes ex-
cessive force. 135 F. 4th 19, 35 (2025). It remanded for a
jury trial against Zorn. Judge Cabranes dissented. “The
case before us is not an exceptional case,” Judge Cabranes
reasoned, but “a routine arrest and removal.” Id., at 41.
II
Government offcials enjoy qualifed immunity from suit
under § 1983 unless their conduct violates clearly established
law. Rivas-Villegas v. Cortesluna, 595 U. S. 1, 5 (2021) (per
showing that “[w]hen the suspects used slight resistance, most incidents
involved offcer use of verbal commands, handcuffng, or wrist/arm locks”).
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572 ZORN
v. LINTON
Per Curiam
curiam). “A right is clearly established when it is `suff-
ciently
clear that every reasonable offcial would have under-
stood that what he is doing violates that right.' ” Ibid. A
right is not clearly established if existing precedent does not
place the constitutional question “ `beyond debate.' ” Ibid.
To fnd that a right is clearly established, courts generally
“need to identify a case where an offcer acting under similar
circumstances . . . was held to have violated” the Constitu-
tion. Escondido v. Emmons, 586 U. S. 38, 43 (2019) (per cu-
riam) (internal quotation marks omitted). The relevant
precedent must defne the right with a “high degree of speci-
fcity,” so that “every reasonable offcial would interpret it
to establish the particular rule the plaintiff seeks to apply.”
District of Columbia v. Wesby, 583 U. S. 48, 63 (2018) (inter-
nal quotation marks omitted). Principles stated generally,
such as that “an offcer may not use unreasonable and exces-
sive force,” do not suffce. Kisela v. Hughes, 584 U. S. 100,
105 (2018) (per curiam). In short, offcers receive qualifed
immunity unless they could have “read” the relevant prece-
dent beforehand and “know[n]” that it proscribed their
specifc conduct. City and County of San Francisco v.
Sheehan, 575 U. S. 600, 616 (2015).
The Second Circuit contravened these principles. Am-
nesty America did not clearly establish that Zorn's specifc
conduct violated the Fourth Amendment.
3
Whether any
particular use of force violates the Fourth Amendment de-
pends on “the facts and circumstances of each particular
case,” Graham v. Connor, 490 U. S. 386, 396 (1989), including
whether the offcer gave “warnings” before using force,
Barnes v. Felix, 605 U. S. 73, 80 (2025). In Amnesty
America, the court considered a wide range of allegations of
excessive force. The offcers rammed a protester's head into
a wall, dragged another protester across the ground, and
3
We assume without deciding that “controlling Circuit precedent” can
clearly establish law for qualifed-immunity purposes. Rivas-Villegas v.
Cortesluna, 595 U. S. 1, 5 (2021) (per curiam).

Cite
as: 607 U. S. 568 (2026)
573
Per Curiam
used rear wristlocks on two more protesters to lift them up
before
throwing one of them to the ground. 361 F. 3d, at
123. Nothing indicated that the offcers 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. In-
stead, it remanded for a jury trial because, while a “reason-
able jury could . . . fnd that the offcers gratuitously inficted
pain,” it was also “entirely possible that a reasonable jury
would fnd . . . that the police offcers' use of force was objec-
tively reasonable given the circumstances.” Id., at 124 (em-
phasis added). Relevant here, Amnesty America even
relied on a decision approving the practice of warning
protesters and then using wristlocks to move them. Ibid.
(citing Forrester v. San Diego, 25 F. 3d 804, 807–808 (CA9
1994)).
Reasonable officia ls wou ld not “ i nter pret [Amnesty
America] to establish” that using a routine wristlock to move
a resistant protester after warning her, without more, vio-
lates the Constitution. Wesby, 583 U. S., at 63; see Sheehan,
575 U. S., at 615–616. 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 wristlock to bring Linton
to her feet. See App. to Pet. for Cert. 47–49. Amnesty
America never “held” that such conduct alone “violated” the
Fourth Amendment. Emmons, 586 U. S., at 43 (internal
quotation marks omitted). If anything, it implied the oppo-
site. See Amnesty America, 361 F. 3d, at 124 (citing Forres-
ter, 25 F. 3d, at 807–808). And its statement that offcers
who had engaged in a wide range of aggressive conduct may
have used excessive force did not “put [Zorn] on notice that
his specifc conduct was unlawful.” Rivas-Villegas, 595
U. S., at 6.
The Second Circuit concluded otherwise by reading Am-
nesty America to establish the general principle “that the
gratuitous use of pain compliance techniques—such as a rear-
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574 ZORN
v. LINTON
Sotomayor, J., dissenting
wristlock—on a protestor who is passively resisting arrest
constitutes
excessive force.” 135 F. 4th, at 35 (case below).
But that principle, even assuming Amnesty America estab-
lished it, lacks the “high degree of specifcity” needed to
make it “clear” to offcers which actions violate the law.
Wesby, 583 U. S., at 63 (internal quotation marks omitted).
It does not “obviously resolve” whether using a rear wrist-
lock to move a noncompliant protester after repeated warn-
ings violates the Fourth Amendment, id., at 64, as it fails
to specify which circumstances make the use of force
“gratuitous.”
Because the Second Circuit failed to identify a case where
an offcer taking similar actions in similar circumstances
“was held to have violated” the Constitution, Emmons, 586
U. S., at 43 (internal quotation marks omitted), Zorn was
entitled to qualifed immunity. We grant his petition for
writ of certiorari and reverse the judgment of the Second
Circuit.
It is so ordered.
Justice Sotomayor, with whom Justice Kagan and
Justice Jackson join, dissenting.
Sergeant Jacob Zorn used a “ `pain compliance technique' ”
called a rear wristlock on Shela Linton, a nonviolent pro-
testor who was peacefully demonstrating at a sit-in in the
Vermont capitol. 135 F. 4th 19, 24–25 (CA2 2025). The
Second Circuit held that Zorn was not entitled to qualifed
immunity on Linton's Fourth Amendment excessive force
claim, at least at the summary judgment stage, because prior
Circuit precedent had clearly established that using a rear
wristlock against a nonviolent protestor would violate the
protestor's constitutional rights. That decision was not er-
roneous, and certainly not so clearly erroneous as to warrant
the “extraordinary remedy of a summary reversal.” Major
League Baseball Players Assn. v. Garvey, 532 U. S. 504, 512–
513 (2001) (Stevens, J., dissenting). I respectfully dissent.
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Cite
as: 607 U. S. 568 (2026)
575
Sotomayor, J., dissenting
I
Given
that this case is at the summary judgment stage,
the Court must “view the evidence . . . in the light most
favorable to” Linton, the nonmovant, “with respect to the
central facts of this case.” Tolan v. Cotton, 572 U. S. 650,
657 (2014) (per curiam). Before Sergeant Zorn's interaction
with Linton, offcers had arrested 15 or 16 demonstrators:
The “offcers tapp[ed] some of the demonstrators' shoulders
or sp[oke] briefy with them before the offcers placed them
under arrest.” App. to Pet. for Cert. 44 (App.). “Some of
the arrestees voluntarily stood up after offcers approached
them,” while the “[o]ffcers lifted the demonstrators who did
not stand up voluntarily and escorted, dragged, or carried
them out of the chamber.” Ibid. “Consistent with the con-
cept of a nonviolent sit-in protest, . . . none of [the demonstra-
tors] attacked the offcers or used any form of violence.”
Id., at 45. One offcer, Trooper Richardson, described the
“level of safety threat in the environment [as] `[v]ery low.' ”
Ibid. (alteration in original).
When Zorn and Richardson frst approached Linton, they
“did not issue any `clear request or command,' ” and the
“video evidence appears to indicate that” one of them said
only, “ `ma'am?' ” Id., at 46. About fve seconds later, Zorn
and Richardson unlinked Linton's arms from the other dem-
onstrators' arms. Without any warning—indeed, without
saying another word to Linton—Zorn placed Linton's left
arm into a rear wristlock by twisting her arm and shoulder,
“snapp[ing]” her wrist, and “ `forc[ing] it down and to the
rear.' ” Id., at 47; Plaintiff 's Supp. Affdavit in No. 5:18–cv–
5 (D Vt.), ECF Doc. 74–3, p. 2. Linton immediately ex-
claimed, “ `ow, ow, ow!' ” App. 47. Only then did Zorn
instruct Linton to “ `please stand up.' ” Id., at 48.
Linton did not stand up, at which point Zorn further twis-
ted Linton's arm. “Linton's face contorted in pain as she
stated, `my arm!' or `don't twist my arm!' ” Ibid. Zorn
asked Linton to stand up several more times. Linton re-
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576 ZORN
v. LINTON
Sotomayor, J., dissenting
fused and replied: “ `You're hurting me.' ” Ibid. Zorn then
war
ned Linton: “ `I'm going to ask you one more time . . .
and then I will use more pain compliance.' ” Ibid. Linton
repeated that Zorn was “ `hurting ' ” her and did not move to
stand up. Id., at 49. Zorn then applied pressure to Lin-
ton's wrist and lifted her upward, causing Linton to “con-
tor[t] her face in pain and . . . scream very loudly.” Ibid.
Zorn whispered to her that “she should have called her legis-
lator.” Ibid.
After being hauled to her feet, Linton collapsed back onto
the foor “due to pain and feeling weak.” Id., at 50. Zorn,
Richardson, and a third offcer “lifted” her “by her arms and
legs and carried her out of the House chamber” without fur-
ther use of a rear wristlock or any other pain-compliance
technique. Id., at 51. As a result of this event, Linton “suf-
fered permanent damage to her left wrist and shoulder” and
has been “diagnosed with post-traumatic stress disorder, de-
pression, and anxiety.” 135 F. 4th, at 25.
II
Offcers are not entitled to qualifed immunity if “(1) they
violated a federal statutory or constitutional right, and
(2) the unlawfulness of their conduct was `clearly established
at the time.' ” District of Columbia v. Wesby, 583 U. S. 48,
62–63 (2018). The Second Circuit correctly held that sum-
mary judgment must be denied because a jury could fnd that
Zorn violated Linton's clearly established Fourth Amend-
ment rights.
A
Starting with the frst prong of the qualifed immunity
analysis, Linton contends that Zorn violated her Fourth
Amendment rights by using excessive force during her ar-
rest. Determining whether a given use of force is excessive
requires a “careful balancing of ` “the nature and quality of
the intrusion on the individual's Fourth Amendment inter-
ests” ' against the countervailing governmental interests at
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as: 607 U. S. 568 (2026)
577
Sotomayor, J., dissenting
stake.” Graham v. Connor, 490 U. S. 386, 396 (1989). The
i
nquiry depends on the “ `totality of the circumstances,' ” “in-
cluding the severity of the crime at issue, whether the sus-
pect poses an immediate threat to the safety of the offcers
or others, . . . whether [s]he is actively resisting arrest or
attempting to evade arrest by fight,” ibid., the “relationship
between the need for the use of force and the amount of force
used[, and] the extent of [her] injury,” Kingsley v. Hendrick-
son, 576 U. S. 389, 397 (2015).
Here, the Second Circuit rightly concluded that a reason-
able jury could fnd that Zorn's use of force was excessive in
violation of the Fourth Amendment. See 135 F. 4th, at 36.
First, the crime of trespass for which Linton was arrested is
not “ `particularly severe.' ” Ibid. Second, it is undisputed
that the threat to safety posed by Linton was relatively low.
Trooper Richardson described the level of safety risk as
“ `[v]ery low.' ” Ibid. The protestors also “passed through
security (and therefore must have been considered to be un-
armed), did not signifcantly outnumber police,” and were
“not accused of being volatile or violent.” Ibid. Third, it
is also undisputed that Linton “suffered permanent loss of
motion in her left wrist and shoulder as a result of the inci-
dent.” Ibid. Fourth, there is a material dispute of fact as
to whether Linton was actively resisting arrest, and a jury
reasonably could conclude that Linton was only passively re-
sisting and that her failure to comply was because she was
“in too much pain to do so.” Id., at 37. Finally, a jury also
reasonably could conclude that the use of pain compliance
was not “reasonably related to any need to use force.” Id.,
at 38. The offcers purportedly “did not use pain compliance
techniques in the arrests of . . . fellow protestors,” and Lin-
ton contends that “the Vermont State Police use-of-force pol-
icy does not suggest . . . us[ing] pain compliance techniques
in response to passive resistance.” Ibid. Further, Zorn's
own expert stated that “the general police practice in re-
sponse to passive resistance is `low level physical contact . . .
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578 ZORN
v. LINTON
Sotomayor, J., dissenting
with little or no pain.' ” Ibid. Taken together, a jury could
reasonably
conclude that Zorn used excessive force in viola-
tion of Linton's Fourth Amendment rights.
B
The second prong of the qualifed immunity analysis asks
whether the “unlawfulness of [the offcial's] conduct was
`clearly established at the time,' ” Wesby, 583 U. S., at 63,
which requires assessing whether the “contours of the right
[are] suffciently clear that a reasonable offcial would under-
stand that what he is doing violates that right,” Anderson v.
Creighton, 483 U. S. 635, 640 (1987). “[E]arlier cases involv-
ing `fundamentally similar' facts can provide especially
strong support for a conclusion that the law is clearly estab-
lished,” Hope v. Pelzer, 536 U. S. 730, 741 (2002), but there
need not be a “ ` “case directly on point,” ' ” White v. Pauly,
580 U. S. 73, 79 (2017) (per curiam).
In addition to the long-established principle that offcers
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 gratu-
itous use of pain compliance techniques—such as a rear-
wristlock—on a protestor who is passively resisting arrest
constitutes excessive force.” 135 F. 4th, at 35. In that case,
offcers 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 offcers 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: Offcers
“lift[ed] and pull[ed]” them off the foor “by pressing their
wrists back against their forearms in a way that caused last-
ing damage.” Id., at 123. The Circuit then held that, under
past cases, “allegations involving comparable amounts of
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Cite
as: 607 U. S. 568 (2026)
579
Sotomayor, J., dissenting
force used during the arrest of a nonviolent suspect are suf-
fcient
to allow a reasonable factfnder to conclude that the
force used was excessive.” Id., at 123–124.
Amnesty America's specifc discussion of rear wristlocks
thus clearly established that using a rear wristlock against
a nonviolent, passively resisting protestor could constitute
excessive force. It therefore put Zorn on notice, to a “high
`degree of specifcity,' ” Wesby, 583 U. S., at 63, that using the
same technique against a passively resisting protestor like
Linton would expose him to liability for violating Linton's
Fourth Amendment rights.
C
The Court's attempts to distinguish Amnesty America are
mistaken. It frst claims that Amnesty America differs
from this case because the offcers 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 warn-
ings: It observed that the “police purportedly employed” the
pain-compliance techniques “only after they were unsuccess-
ful 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”). Amnesty America thus involved “ `an offcer
acting under similar circumstances,' ” Escondido v. Em-
mons, 586 U. S. 38, 43 (2019) (per curiam), and put Zorn on
notice that his actions would violate established law.
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 opin-
ion does not specify whether similar warnings were given
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580 ZORN
v. LINTON
Sotomayor, J., dissenting
after the initiation of the wristlocks. If that is the differ-
ence
on which the majority relies, the majority is essentially
requiring Linton to fnd a factually identical case, a require-
ment that this Court has repeatedly rejected. See, e. g., An-
derson, 483 U. S., at 640 (“This is not to say that an offcial
action is protected by qualifed immunity unless the very ac-
tion 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).
The majority also suggests that Amnesty America consid-
ered a “wide range” of conduct, implying that it did not spe-
cifcally address rear wristlocks like the one at issue here.
Ante, at 572. That, too, is inconsistent with the actual opin-
ion, which recognized that each plaintiff had “standing to
assert only those constitutional deprivations that they them-
selves [were] alleged to have suffered” and specifcally iden-
tifed the use of a rear wristlock against some passively re-
sisting protestors as “suffcient to allow a reasonable
factfnder to conclude that the force used was excessive.”
361 F. 3d, at 123–124, and n. 6.
The Court next reasons that Amnesty America did not
clearly establish any law because it stated that while a “rea-
sonable jury could . . . fnd that the offcers” used excessive
force, it was also “entirely possible that a reasonable jury
would fnd . . . that the police offcers' use of force was objec-
tively reasonable given the circumstances and the plaintiffs'
resistance techniques.” Id., at 124; see ante, at 573–574.
These statements in Amnesty America, however, refect
that the Second Circuit was reviewing a district court's grant
of summary judgment in favor of the defendants where there
was factual uncertainty. In reversing the grant of summary
judgment, the Second Circuit held that if the plaintiffs' alle-
gations were true, they would be “suffcient to allow a rea-
sonable factfnder to conclude that the force used was exces-
sive,” but it found that there were material disputes on
“issues of fact” that could not be resolved at summary judg-
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Cite
as: 607 U. S. 568 (2026)
581
Sotomayor, J., dissenting
ment. 361 F. 3d, at 123–124. Thus, when Amnesty
Ame
rica stated that a reasonable jury could rule for the of-
fcers, it was merely acknowledging the reality that the jury
might well resolve those material factual disputes in favor of
the defendants and fnd that the offcers' use of force, under
the circumstances that truly occurred, was not excessive.
Id., at 124. That possibility, however, does not change the
fact that the Second Circuit held the use of a wristlock could
be excessive if events had transpired the way plaintiffs al-
leged they had in that case. See 135 F. 4th, at 33. Indeed,
the Second Circuit has long held that “a vacatur of a grant
of summary judgment and a remand in light of the existence
of genuine issues of material fact” may clearly establish a
constitutional violation, id., at 34, and the dissent below
agreed, id., at 40 (Cabranes, J., concurring in part and dis-
senting in part).
At bottom, the majority's analysis rests on the assumption
that the law can be clearly established only by factually iden-
tical “ ` “case[s] directly on point,” ' ” despite the Court's re-
jection of such a standard. White, 580 U. S., at 79. Instead,
it is “enough that governing law places `the constitutionality
of the offcer's conduct beyond debate.' ” Kisela v. Hughes,
584 U. S. 100, 120 (2018) (Sotomayor, J., dissenting) (quoting
Wesby, 583 U. S., at 63). Here, taking the facts in the light
most favorable to Linton, it is “beyond debate” that Zorn's
use of pain compliance against the passively resisting Linton
was excessive. Accordingly, Zorn was not entitled to sum-
mary judgment based on qualifed immunity.
***
For the foregoing reasons, the Second Circuit did not err
in holding that Zorn is not entitled to qualifed immunity at
this stage. At the very least, the decision below was not so
wrong as to warrant the “extraordinary remedy of a sum-
mary reversal.” Garvey, 532 U. S., at 512–513 (Stevens, J.,
dissenting). Relying on disputed facts, the Court today sim-

582 ZORN
v. LINTON
Sotomayor, J., dissenting
ply disagrees with how the Second Circuit applied a correctly
st
ated legal standard (the requirement that law be estab-
lished to “ `a high degree of specifcity' ” in the qualifed im-
munity analysis) to this particular set of facts. 135 F. 4th,
at 32 (quoting Wesby, 583 U. S., at 63). That is a routine,
and nowhere near extraordinary, dispute that did not require
the Court's intervention.
In the past, I have noted the “troubling asymmetry” in
this Court's “unfinching willingness `to summarily reverse
courts for wrongly denying offcers the protection of quali-
fed immunity' but `rarely interven[ing] where courts
wrongly afford offcers the beneft of qualifed immunity.' ”
Kisela, 584 U. S., at 121 (Sotomayor, J., dissenting). This
case unfortunately represents a resurgence and perpetuation
of this “one-sided approach to qualifed immunity” that
“transforms the doctrine into an absolute shield for law en-
forcement offcers, gutting the deterrent effect of the Fourth
Amendment.” Ibid. The majority today gives offcers li-
cense to infict gratuitous pain on a nonviolent protestor even
where there is no threat to offcer safety or any other reason
to do so. That is plainly inconsistent with the Fourth
Amendment's fundamental guarantee that offcers may only
use “the amount of force that is necessary” under the circum-
stances. Graham, 490 U. S., at 396. Therefore, I respect-
fully dissent.
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Reporter’s Note
The attached opinion has been revised to refect the usual publication
and citation style of the United States Reports. The revised pagination
makes available the offcial United States Reports citation in advance of
publication. The syllabus has been prepared by the Reporter of Decisions
for the convenience of the reader and constitutes no part of the opinion of
the Court. A list of counsel who argued or fled briefs in this case, and
who were members of the bar of this Court at the time this case was
argued, has been inserted following the syllabus. Other revisions may
include adjustments to formatting, captions, citation form, and any errant
punctuation. The following additional edits were made:
p. 575, line 4: “the” is changed to “this”