Linton v. Zorn: Pain-Compliance on Passive Resistors Exceeds Fourth Amendment Bounds

Introduction

The Second Circuit’s April 24, 2025 decision in Linton v. Zorn arises out of a January 2015 sit-in protest at the Vermont Statehouse. Forty-six-year-old demonstrator Shela M. Linton remained seated, arms linked with fellow protestors, when law-enforcement officers moved in to clear and arrest the noncompliant participants. Sergeant Jacob P. Zorn used a “rear wristlock” pain-compliance hold to disengage Ms. Linton’s linked arms and then to compel her to stand, inflicting permanent wrist and shoulder injuries. On summary judgment the District Court awarded Sergeant Zorn qualified immunity, concluding that no “clearly established” precedent had put him on notice that his conduct was unlawful. Ms. Linton appealed, arguing both (1) that Amnesty America v. Town of West Hartford (2d Cir. 2004) did clearly establish the right and (2) that factual disputes about her level of resistance and the reasonableness of force precluded summary judgment. A divided Second Circuit panel agreed with Ms. Linton, vacated the grant of immunity, and remanded for trial.

Summary of the Judgment

By a 2–1 vote, the Court held that:

Clearly Established Law: Amnesty America had already “warned officers against gratuitously employing ‘pain compliance techniques’—such as bending wrists or rear wristlocks—on protestors who are merely passively resisting.”
Material Factual Disputes: Video and deposition evidence present genuine disputes over whether Ms. Linton’s conduct was active versus passive resistance, whether the degree of force bore a reasonable relationship to the need, and whether Sergeant Zorn acted in bad faith. Those disputes must be resolved by a jury, not on summary judgment.
Remedy: Vacate the District Court’s grant of qualified immunity and remand for further proceedings consistent with the opinion—particularly, interrogatories to the jury on key contested facts.

Analysis

Precedents Cited

Amnesty America v. Town of West Hartford (361 F.3d 113, 2d Cir. 2004) – Held that rear wristlocks and similar pain-compliance on passively resisting protestors could constitute excessive force under the Fourth Amendment.
Graham v. Connor (490 U.S. 386, 1989) – Established the “objective unreasonableness” test, balancing force used against governmental interests.
Figueroa v. Mazza (825 F.3d 89, 2d Cir. 2016) – Added factors such as necessity, relationship of need to force, severity of injury, and good-faith versus malicious use.
Tracy v. Freshwater (623 F.3d 90, 2d Cir. 2010) – Clearly established that deploying pepper spray against a non-resisting or compliant suspect is excessive force.
Edrei v. Maguire (892 F.3d 525, 2d Cir. 2018) – Confirmed that “pain-compliance” devices used on protesters are subject to the Fourth Amendment and that Amnesty America had given fair warning.
Scott v. Harris (550 U.S. 372, 2007) – Video evidence must be credited when it “blatantly contradicts” a party’s version of events.

Legal Reasoning

The Court applied the two-pronged qualified immunity analysis:

Constitutional Violation? The use of a “rear wristlock” on a demonstrator who had not threatened officers and who was resisting only by remaining seated potentially violated the Fourth Amendment’s prohibition on unreasonable seizures; force plainly beyond that needed to effect a peaceful arrest can be “objectively unreasonable.”
Clearly Established? Amnesty America had already placed officers on notice that pain-compliance holds on passive resistors could be excessive force. A law enforcement officer in Sergeant Zorn’s position “would understand that what he is doing violates [the] right.”

Because genuine disputes of material fact remain—most notably the factual narrative of whether Ms. Linton’s arm movements were involuntary pain responses or active resistance, and whether Sergeant Zorn applied force in good faith—the Court declined to decide as a matter of law how those facts would resolve the constitutional question. Instead, it ordered those disputes be submitted to a fact-finder before any final qualified immunity ruling.

Impact

Reinforces that “pain compliance techniques,” including wristlocks, are not categorically lawful. Officers risk personal liability unless they have clear precedent justifying such force.
Emphasizes the importance of video evidence and careful framing of factual disputes at summary judgment in use-of-force cases.
Encourages trial courts to employ jury interrogatories to resolve contested facts before disposing of qualified immunity claims.
Signals to law-enforcement agencies that training and policies must specifically address passive resistance and prohibit pain-compliance absent clear exigencies.
May lead to more Fourth Amendment excessive-force trials where video shows contested levels of resistance but officers assert qualified immunity.

Complex Concepts Simplified

Qualified Immunity: Protects government officials from civil liability unless they violate “clearly established” rights that a reasonable person would know.
Passive Resistance: Non-violent, non-compliant behavior (e.g., going limp, remaining seated) that does not threaten officers.
Pain-Compliance Technique: A controlled hold (such as a rear wristlock) designed to cause discomfort and force submission.
Rear Wristlock: A lever applied to the back of the hand and wrist, forcing the joint into an uncomfortable position to achieve control.
Summary Judgment: A court decision without trial when no “genuine dispute” of material fact exists and one party is entitled to judgment as a matter of law.
“Clearly Established” Law: Precedent sufficiently precise that “every reasonable officer” would recognize the conduct as unlawful.

Conclusion

Linton v. Zorn marks a significant reaffirmation that the Fourth Amendment limits law-enforcement to force proportionate to the resistance encountered. Pain-compliance holds on peacefully resisting protestors are not immune from liability unless authorities can point to case law squarely approving such conduct. By vacating the District Court’s summary-judgment grant and remanding for factual resolution, the Second Circuit underscores the dual need to respect qualified immunity’s protective scope while ensuring that demonstrators retain enforceable Fourth Amendment rights against gratuitous pain-inflicting tactics.