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

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. Lint on’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, pullin g 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 wi th this Court’s re peated instruction that courts must define rights with specificity and look for close factual analogues in determining whether a Fourth Amendment right is clearly established.