A Jahn-Teller distortion is predicted whenever a non-linear symmetric molecule has degenerate orbitals and has unequal electron occupation in those degenerate orbitals. Of course, this most often is discussed in the context of octahedral complexes, but it also occurs in other species - it's a general effect.
When I was teaching inorganic chemistry this term, my students asked if this could occur in square planar complexes. My immediate answer was "yes because, of course, there are degenerate MOs:"
Later, I was trying to figure out what the exact geometric distortion would be. As Wikipedia notes:
Jahn–Teller theorem does not predict the direction of the distortion, only the presence of an unstable geometry.
I consulted the Walsh diagram posted above from Orbital Interactions in Chemistry by Albright, Burdett, and Whangbo.
My initial inclination would be a "scissor" distortion towards a tetrahedral shape since I know $\ce{T_d}$ complexes undergo similar Jahn-Teller distortions.
Based on the Walsh diagram, depending on the electron count (e.g., $\ce{d^3}$ as suggested by the students) it seems as if you would always have a Jahn-Teller distortion predicted, because you would have at least 1 electron in the $\ce{2e}$ orbitals (the structure would be $\ce{D_{2d}}$ as indicated in the figure.
I understand based on LFSE, such complexes wouldn't be stable, but the question remains: Wouldn't it drop down to $\ce{C_{2V}}$ to break degeneracy? If so, how?
What is the specific geometric Jahn-Teller distortion for unstable (e.g., $\ce{d^3}$ square planar complexes?