Zorn v. Linton

The Supreme Court decided Zorn v. Linton on March 23, 2026, in a per curiam opinion. The Court held that Sergeant Jacob Zorn was entitled to qualified immunity and reversed the Second Circuit because earlier case law did not clearly establish that his specific use of a wristlock violated the Fourth Amendment.

Qualified immunity can block damages suits against officers unless prior law clearly warned that the conduct was unconstitutional. The ruling matters for protest policing and excessive-force lawsuits because it reinforces how specific earlier precedent must be.

The case fits the Court's strict approach to clearly established law in qualified-immunity cases. It also shows the tension between police accountability claims and the Court's demand for close factual matches in earlier cases.

The Court issued a per curiam decision reversing the Second Circuit. Justice Sotomayor dissented, joined by Justices Kagan and Jackson.

“Zorn was entitled to qualified immunity.”

“The Second Circuit correctly held that summary judgment must be denied.”

The officer won at the Supreme Court. Linton's excessive-force claim cannot proceed against him on this record because the Court found the law was not clearly established enough to overcome qualified immunity.

The Supreme Court's docket shows judgment issued on April 24, 2026. The lower courts must follow the reversal, so the qualified-immunity ruling ends this claim against Zorn unless a separate procedural path remains.

The dispute was whether Sergeant Jacob Zorn could be sued after using a wristlock to remove Shela Linton from a Vermont state capitol sit-in. The Supreme Court focused on whether earlier law clearly established that this specific force was unconstitutional.

Police officers get stronger protection when prior cases do not closely match the facts they faced. Protesters and civil-rights plaintiffs face a higher burden when suing over force used during arrests or removals.

The Court applied qualified immunity, which shields officials from damages unless the violated right was clearly established. It required a close factual analogue showing that similar conduct had already been held unconstitutional.

The Supreme Court reversed the Second Circuit and issued judgment on April 24, 2026. That sends the case back under a ruling that Zorn is entitled to qualified immunity.

The decision continues the Court's pattern of requiring specific precedent before officers lose qualified immunity. It narrows the room for lower courts to rely on broad excessive-force principles alone.