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Jacob P. Zorn v. Shela M. Linton
Paid petition · United States Court of Appeals for the Second Circuit, No. 22-2954 · judgment April 24, 2025
Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.
Question presented
During a demonstration at the Vermont State House, State Police Sergeant Jacob Zorn used a common pain compliance technique called a wristlock to facilitate the removal of Shela Linton from the House chamber. Reviewing Ms. Linton’s subsequent excessive force claim, the Second Circuit held that Sergeant Zorn’s conduct was governed by Amnesty America v. Town of West Hartford, 361 F3.d 113 (2d Cir. 2004), where the court allowed an excessive force claim to proceed based on allegations that municipal police officers did things like kneeling on protesters’ backs, stepping on their heads, pulling their hair, and slamming them face-first onto the ground and against walls. The question presented is: Whether the Second Circuit’s qualified immunity analysis conflicts with this Court’s repeated instruction that courts must define rights with specificity and look for close factual analogues in determining whether a Fourth Amendment right is clearly established. (i)
Counsel of record
For petitioner
Jonathan Todd Rose
Office of the Vermont Attorney General
For respondent
Keegan James Stephan
Beldock Levine & Hoffman, LLP
Case
Conference history
Distributed for 10 conferences
Proceedings
- Apr 24 2026Judgment Issued.
- Mar 23 2026Petition GRANTED. Judgment REVERSED. Opinion per curiam. (Detached Opinion) Justice Sotomayor, with whom Justice Kagan and Justice Jackson join, dissenting. (Detached Opinion)
- Mar 16 2026DISTRIBUTED for Conference of 3/20/2026.
- Mar 02 2026DISTRIBUTED for Conference of 3/6/2026.
- Mar 02 2026Electronic record received from the U.S. Court of Appeals for the Second Circuit.
- Mar 02 2026Electronic record received from the U.S. District Court for the District of Vermont.
- Feb 27 2026Record Requested.
- Feb 23 2026DISTRIBUTED for Conference of 2/27/2026.
- Feb 13 2026DISTRIBUTED for Conference of 2/20/2026.
- Jan 20 2026DISTRIBUTED for Conference of 1/23/2026.
- Jan 12 2026DISTRIBUTED for Conference of 1/16/2026.
- Jan 05 2026DISTRIBUTED for Conference of 1/9/2026.
- Dec 08 2025DISTRIBUTED for Conference of 12/12/2025.
- Nov 18 2025DISTRIBUTED for Conference of 12/5/2025.
- Nov 14 2025Reply of petitioner Jacob P. Zorn filed. (Distributed)
- Nov 03 2025Brief of respondent Shela M. Linton in opposition filed.
- Oct 02 2025Response Requested. (Due November 3, 2025)
- Oct 01 2025DISTRIBUTED for Conference of 10/17/2025.
- Sep 16 2025Waiver of right of respondent Shela M. Linton to respond filed.
- Sep 11 2025Petition for a writ of certiorari filed. (Response due October 15, 2025)