Zorn v. Linton

Summary

The Court, per curiam, summarily reversed the Second Circuit and held that Sergeant Zorn was entitled to qualified immunity because existing precedent did not clearly establish that using a wristlock to lift a resistant protester after repeated warnings violated the Fourth Amendment. Amnesty America did not establish the asserted prohibition with sufficient specificity. The Court did not decide whether Zorn's conduct actually violated the Fourth Amendment. Justice Sotomayor dissented, joined by Justices Kagan and Jackson, arguing that Amnesty America supplied sufficiently specific notice, that the Court improperly relied on disputed facts concerning warnings and resistance, and that summary reversal was unwarranted.