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Decision record

Qualified immunity requires close factual correspondence, not abstract generality

Case: Jacob P. Zorn, Petitioner v. Shela M. LintonComparison published: 2026-04-27 No lead time is claimed for this record. The underlying determination is not individually identifiable in the Substack export, so no lead time is claimed for this record. The decisive question Did existing precedent clearly establish that this specific wristlock-removal sequence, following warning and…

Record Boundary

The status, NLI role, publication authority, observed result, material limitations, version, and correction path below define what this record may responsibly claim.

Status
Comparative determination
Application
Comparative determination
Forum / context
Supreme Court of the United States · Comparative determination

Decisive question

Did existing precedent clearly establish that this specific wristlock-removal sequence, following warning and passive resistance, violated the Fourth Amendment?

Controlling dependency

Whether the precedent relied on below described conduct similar enough to the officer's actual sequence to place the question beyond debate.

Defeat condition

A precedent addressing materially similar removal conduct would have defeated the qualified-immunity conclusion.

Case: Jacob P. Zorn, Petitioner v. Shela M. Linton
Comparison published: 2026-04-27

No lead time is claimed for this record. The underlying determination is not individually identifiable in the Substack export, so no lead time is claimed for this record.

The decisive question

Did existing precedent clearly establish that this specific wristlock-removal sequence, following warning and passive resistance, violated the Fourth Amendment?

The controlling dependency

Whether the precedent relied on below described conduct similar enough to the officer’s actual sequence to place the question beyond debate.

The defeat condition

A precedent addressing materially similar removal conduct would have defeated the qualified-immunity conclusion.

How it compared

Full alignment. The published determination — certiorari granted, Second Circuit reversed, qualified immunity available — matched the Court’s disposition and its stated rule.

NLI’s role

Published analysis only. No participation in the case.

Limits of this record

NLI was not counsel, a party, or a participant in this case, and filed nothing in it. This record establishes only that NLI published the stated determination on the stated date and how that determination compared with the decision the Court later reached. It does not establish that NLI influenced the outcome, that NLI’s reasoning was adopted, or that a comparable result should be expected in any other matter.

Read the full comparison on Substack