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Mar 19, 2026

Supreme Court Strengthens Protections for ICE Officers

The U.S. Supreme Court has issued a 6–3 decision in Zorn v. Linton, reinforcing the standard for qualified immunity and reversing a lower court ruling that had denied immunity to a Vermont police officer.

The case arose from a sit-in protest inside the Vermont State House. Protester Shela Linton refused to leave after the building closed for the night. Sgt. Jacob Zorn ordered her to stand and warned that force would be used if she continued to resist. When Linton refused, Zorn placed her arm behind her back in a rear wristlock, applied pressure, and lifted her to her feet.

Linton filed a civil rights lawsuit under 42 U.S.C. § 1983, alleging excessive force in violation of the Fourth Amendment. A federal district court granted summary judgment to Zorn, holding that he was entitled to qualified immunity because it was not “clearly established” that his specific actions were unconstitutional in those circumstances.

The U.S. Court of Appeals for the Second Circuit reversed, relying on a 2004 case, Amnesty America v. West Hartford, which held that the “gratuitous” use of a rear wristlock on a protester passively resisting arrest could constitute excessive force. The Supreme Court reversed the Second Circuit and reinstated qualified immunity for Zorn.

The Court reiterated that government officials are shielded from civil liability unless they violate “clearly established” law. To meet that standard, courts generally must identify a prior case where an officer acting under similar circumstances was held to have violated the Constitution.

The justices concluded that Amnesty America did not clearly establish that Zorn’s conduct — lifting a noncompliant protester using a wristlock after warning that force would be applied — violated the Fourth Amendment. The Second Circuit, the Court held, failed to identify precedent involving materially similar facts.

Justice Sonia Sotomayor dissented, joined by Justices Elena Kagan and Ketanji Brown Jackson. The dissent argued that a jury should have been allowed to determine whether the force used was excessive and whether the right at issue was clearly established.

Former House Speaker Nancy Pelosi recently slammed ICE agents and came out against them being stationed to help at San Francisco’s airports.

“It’s completely wrong, ICE agents are not trained for the job they have they’re inadequate for that and they move on to another job, and inadequately trained to be at the airport,” Pelosi said.


The ruling reinforces a demanding standard for overcoming qualified immunity in civil rights cases and signals continued judicial insistence on fact-specific precedent before officers can be held personally liable.

Beyond the immediate case, the decision arrives amid growing political tensions surrounding federal immigration enforcement.

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