The Supreme Court on Monday ruled in favor of a Vermont police officer in an excessive-force case, reinforcing the legal standard for qualified immunity and limiting when such claims can proceed to trial.
In a 6-3 unsigned decision, the Court held that Sgt. Jacob Zorn was entitled to qualified immunity after using a wristlock to remove a protester during a 2015 sit-in at the Vermont State House. The ruling reversed a decision by the U.S. Court of Appeals for the Second Circuit, which had allowed the lawsuit to move forward.
The central legal question was whether Zorn’s actions violated “clearly established” law under the Fourth Amendment. The Supreme Court concluded that they did not.
The justices emphasized that for an officer to lose qualified immunity, there must be prior case law closely matching the specific circumstances, providing clear notice that the conduct in question is unconstitutional.
The lower court had relied on broader precedent suggesting that using force against a nonviolent, passively resisting protester could be excessive. However, the Supreme Court rejected that reasoning, stating that those earlier rulings did not sufficiently mirror the situation Zorn encountered.
The case stems from a 2015 protest inside the Vermont State House, where demonstrators refused to leave after closing hours. Protester Shela Linton remained seated and linked arms with others. According to the record, Zorn warned her before applying a wristlock and lifting her to her feet to remove her from the chamber. Linton later filed suit, alleging both physical and psychological harm.
The Court’s decision effectively ends the case before trial, underscoring that qualified immunity hinges not on whether force appears excessive in hindsight, but on whether existing legal precedent clearly prohibited the specific action at the time it occurred.
In dissent, Justices Sonia Sotomayor, Elena Kagan, and Ketanji Brown Jackson argued that the majority applied the doctrine too rigidly and prematurely. Sotomayor wrote that the decision denies a jury the opportunity to assess whether the force used was reasonable, and warned that such rulings risk expanding qualified immunity into what she described as an overly broad shield for law enforcement.
The majority, however, reaffirmed that without a closely analogous prior ruling establishing the conduct as unconstitutional, claims of excessive force cannot proceed. The decision reinforces a high threshold for plaintiffs seeking to overcome qualified immunity protections in federal court.
