June 2026
The Court further emphasized that the totality of the circumstances must be considered in evaluating the use of force. Here, Sergeant Zorn issued repeated verbal warnings before escalating his use of force and employed a commonly recognized control technique in response to continued noncompliance during a lawful arrest. The Court concluded that no precedent cited by the Second Circuit would have placed a reasonable officer on notice that using a wristlock under these circumstances, after warnings and in response to passive resistance, was unconstitutional.
The Court also rejected the Second Circuit’ s reliance on a broader principle that“ gratuitous” use of pain-compliance techniques against passively resisting individuals constitutes excessive force. Even assuming such a principle could be derived from prior case law, the Court held that it was too general to clearly establish the law for qualified-immunity purposes. The term“ gratuitous,” the Court explained, does not provide meaningful guidance as to when force becomes unlawful, nor does it define the circumstances under which specific techniques cross the constitutional line. Without that level of precision, officers cannot be expected to anticipate liability. Because the Second Circuit failed to identify precedent involving sufficiently similar facts that would have put the constitutional question beyond debate, the Supreme Court held that Sergeant Zorn was entitled to qualified immunity. The judgment of the Second Circuit was reversed.
Takeaway Zorn v. Linton reinforces the Supreme Court’ s consistent instruction that qualified immunity must be analyzed with careful attention to factual detail. The decision does not categorically approve the use of wristlocks or pain-compliance techniques against passively resisting individuals, nor does it foreclose excessive-force claims in similar situations.
Zorn v. Linton 607 U. S. ____( 2026)
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