Shela Linton v. Sargeant Jacob Zorn

Rutland, Vermont, personal injury lawyers represented the Plaintiff who sued on a civil rights theory.

Shela M. Linton sued Jacob P. Zorn claiming that she was wrongfully injured as a direct result of Zorn violated her Fourth Amendment rights by using excessive force.

On the Governor’s inauguration day in Vermont, protest-
ers staged a sit-in at the state capitol. When the capitol
closed for the day, police officers told them that they would
be arrested for trespassing. They refused to leave. As of-
ficers removed the protesters one by one, Sergeant Jacob
Zorn asked Shela Linton to stand up and warned her that
he would eventually have to use force to remove her. She
refused to stand. Zorn took Linton’s arm, put it behind her
back, placed pressure on her wrist, and lifted her to her feet.
Linton sued Zorn for using excessive force, claiming that
the arrest left her with arm injuries and psychological dis-
orders.

The District Court granted summary judgment for Zorn after concluding that
he was entitled to qualified immunity. The District Court reasoned that it was not clearly established at the time of the encounter that, in these circumstances, lifting Linton while putting pressure on her wrist violated the Fourth Amendment.

he Second Circuit reversed. It held that its decision in
Amnesty America v. West Hartford, 361 F. 3d 113 (2004),
clearly established that the “gratuitous” use of a rear wrist-
lock on a protester passively resisting arrest constitutes ex-
cessive force. 135 F. 4th 19, 35 (2025). It remanded for a
jury trial against Zorn.

Reversed