Whether a police officer is entitled to qualified immunity under 42 U.S.C. § 1983 after using a rear wristlock to remove a passively resisting protester who had been given verbal warnings. Specifically, the Court must determine if the Fourth Amendment right against excessive force was "clearly established" in this context. The Court further considers whether the precedent in *Amnesty America v. West Hartford* provided the necessary specificity to put the officer on notice that such conduct was unlawful.

• He is entitled to qualified immunity because his conduct did not violate clearly established law.
• The use of a routine wristlock to move a noncompliant protester after providing repeated verbal warnings does not constitute excessive force under the Fourth Amendment.
• There is no existing precedent involving an officer acting under similar circumstances that defines the right with the "high degree of specificity" required to deny immunity.
• The Second Circuit's reliance on *Amnesty America v. West Hartford* is misplaced because that case involved more severe force and lacked evidence that officers provided warnings.

• The petitioner violated her Fourth Amendment rights by using a "pain compliance technique" against a nonviolent protester who was only passively resisting.
• The law was clearly established by *Amnesty America v. West Hartford*, which indicated that the gratuitous use of rear wristlocks on passively resisting protesters constitutes excessive force.
• The force used was not reasonably related to any need to use force, given that the safety threat in the environment was "very low."
• The petitioner suffered permanent physical damage and psychological injuries, which a jury could find resulted from objectively unreasonable force.

• The Court held that the petitioner is entitled to qualified immunity.
• Government officials enjoy qualified immunity from suit under 42 U.S.C. § 1983 unless their conduct violates "clearly established law," meaning every reasonable official would have understood the action violated a constitutional right (*Rivas-Villegas v. Cortesluna*).
• To find a right clearly established, courts generally must identify a case where an officer acting under "similar circumstances" was held to have violated the Constitution (*Escondido v. Emmons*).
• The relevant precedent must define the right with a "high degree of specificity" so that the rule is "beyond debate" (*District of Columbia v. Wesby*).
• The Court found that *Amnesty America v. West Hartford* did not clearly establish that the petitioner's specific conduct was unlawful because it involved a wider range of aggressive force—such as ramming a protester's head into a wall—and contained no indication that officers gave warnings.
• *Amnesty America* did not definitively hold that the use of force violated the Fourth Amendment, but rather remanded the case for a jury trial.
• The Court noted that *Amnesty America* actually cited *Forrester v. San Diego*, a decision that approved the practice of warning protesters before using wristlocks to move them.
• The general principle that "gratuitous" force is prohibited lacks the specificity needed to resolve whether using a wristlock after repeated warnings is unlawful (*District of Columbia v. Wesby*).