#excessive force

I'm writing about criminal negligence and legal duty, as well as the use of excessive/deadly force especially in relation to the murder of Renee Nicole Good earlier this year (I'm so glad my prof approved my topic) so if anyone is interested in reading it when I'm done...

I've always liked writing essays, especially on things I'm passionate about, which is why I can write them so fast once my brain juices start working (and I work best under pressure). I wrote my previously mentioned 10 page essay over AI in the medical field (very much against it btw, should be illegal imo, you're willing to put human lives in the hands of generally unethical automated generative machines? Tf?)

My main points for this paper though will be focused mostly on definitions of crimes, especially those in Minnesota, though my research has told me that apparently MN doesn't have an excessive force statute, and that they typically just jump straight to murder charges, but they do have regulations on deadly/excessive force

Nonfeasance is also a point I will be talking about, which is failure to act under legal duty. A large portion I hope to focus on regarding the whole situation is failure to act and legal duty, especially since they denied access to a physician to Renee while she was still alive and believe it or not! That's illegal. That alone should be enough to bring charges of failure to act down on them, especially since they also blocked the ambulances from reaching Renee.

This paper is supposed to be primarily analysis, so idk how tf my prof expects me to only write 5-7 pages. Lowkey might ask if I can make it longer if I notice it getting too long bc I don't think it'll be enough to meet the points and make the analysis I believe is deserved for this topic

Supreme Court decided Zorn v. Linton, 607 U. S. __ (2026) on Mon, 23mar26. Opinion was unsigned and J.J. Sotomayor, Kagan, and Jackson dissented. The case considered when police officers are immune from litigation in federal courts over their use of force.

About 200 people linked arms in protest inside Vermont's state capitol. Shela Linton was one of the protestors; Sergeant Jacob Zorn was one of the people tasked with removing the protestors after the building closed for the day.

The officers dealt with them one at a time; some stood up and were escorted out of the chamber without force, but others refused to stand and had to be lifted to their feet or dragged out.

After removing more than a dozen protesters, the officers turned to Linton. Sergeant Jacob Zorn crouched down to speak with her, but she remained seated with her arms interlocked with those of her fellow protesters. As Linton passively resisted, Zorn unlinked her arm from another protester’s, put it behind her back in a rear wristlock, and twisted her arm.2 Linton exclaimed “‘ ow, ow, ow,’” while Zorn repeatedly implored her to “‘please stand up.’” *** After Linton responded, “‘I will not stand up,’” Zorn told her that he would ask “‘one more time’” and then would use more pain compliance. Id., at 48. Linton refused, so Zorn placed pressure on her wrist and lifted her up by her underarm. Linton yelled as she stood up. Once on her feet, Linton continued to jerk her arms and fell back to the floor. Zorn asked her to stand up again, and when she did not, three officers picked her up by her arms and legs and carried her outside. Linton alleged resulting physical and psychological injuries including post-traumatic stress disorder***

Linton sued in federal court for unconstitutional use of excessive force. The trial court granted judgment for Zorn, saying that he had qualified immunity from the litigation. The 2d Circuit reversed saying that he was not eligible for immunity.

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 wristlock on a protester passively resisting arrest constitutes excessive force.*** Government officials enjoy qualified immunity from suit under §1983 unless their conduct violates clearly established law. *** “A right is clearly established when it is ‘sufficiently clear that every reasonable official would have understood that what he is doing violates that right.’” Ibid. A right is not clearly established if existing precedent does not place the constitutional question “‘beyond debate.’”***

The Second Circuit concluded otherwise by reading Amnesty America to establish the general principle “that the gratuitous use of pain compliance techniques—such as a rear-wristlock—on a protestor who is passively resisting arrest constitutes excessive force.” *** But that principle, even assuming Amnesty America established it, lacks the “high degree of specificity” needed to make it “clear” to officers which actions violate the law. *** It does not “obviously resolve” whether using a rear wristlock to move a noncompliant protester after repeated warnings violates the Fourth Amendment, id., at 64, as it fails to specify which circumstances make the use of force “gratuitous.” Because the Second Circuit failed to identify a case where an officer taking similar actions in similar circumstances “was held to have violated” the Constitution, *** Zorn was entitled to qualified immunity. We grant his petition for writ of certiorari and reverse the judgment of the Second Circuit.

In Graham v. Connor, 490 U.S. 386 (1989), the Court said police were immune from federal constitutional litigation for injuring Graham. Graham was a diabetic who was going into diabetic shock. Police thought he was merely drunk and arrested him. In the process "Graham sustained a broken foot, cuts on his wrists, a bruised forehead, and an injured shoulder; he also claims to have developed a loud ringing in his right ear that continues to this day." If the police in that case were immune from suit, it's going to be really hard for someone to win federal constitutional litigation over a wrist lock at a protest.