Zorn v. Linton — Re-decided: Qualified immunity is not a defense to Fourth Amendment excessive-force claims; the reasonableness of the seizure is the sole question.

1) The question is whether Sergeant Zorn's use of a rear wristlock to lift Shela Linton during a passive-resistance protest arrest violated the Fourth Amendment's prohibition on unreasonable seizures. 2) The Fourth Amendment provides: 'The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated.' This text contains no exception for official good faith or lack of clearly established precedent. 3) At ratification, the common law allowed suits against officers for excessive force in arrest; the defense was that the force was objectively reasonable under the circumstances, not that the officer lacked notice of a specific prohibition. See Federalist No. 78 (judicial duty to enforce constitutional limits); 1 Blackstone's Commentaries *123 (officers liable for unreasonable force). 4) The holding: Qualified immunity is not a valid defense to a Fourth Amendment excessive-force claim. The only question is whether the force used was objectively unreasonable under the totality of the circumstances, considering the severity of the crime, the threat posed, and the suspect's resistance. Here, Linton was a nonviolent protester committing a minor trespass, posed no threat, and was passively resisting. Zorn's use of a rear wristlock causing injury, after warnings, may be unreasonable; the case must proceed to a jury on that factual question. 5) Downstream: All excessive-force cases under §1983 will be decided solely on Fourth Amendment reasonableness, without the judge-made qualified-immunity defense. Officers will be liable for unreasonable force regardless of precedent, incentivizing training and de-escalation.