Summary
This Supreme Court per curiam opinion addresses whether an implied cause of action under Bivens extends to Eighth Amendment excessive-force claims brought by federal inmates against prison officials. The Court held that such claims arise in a new context where special factors counsel against judicial extension, particularly given Congress's active legislation in prisoner litigation and the existence of alternative remedial procedures. Consequently, the Court reversed the Fourth Circuit's decision allowing the damages claim to proceed and remanded the case.
Topics
Practice areas
Questions Presented
- Whether Bivens extends to an Eighth Amendment excessive‑force claim for damages against federal prison officials.
- Whether special factors counsel against recognizing such an implied Bivens cause of action.
Holdings
- Bivens does not extend to allow an Eighth Amendment excessive‑force claim for damages against federal prison officials.
Key quotations
“"recognizing a cause of action under Bivens is a disfavored judicial activity."” (942)
“"For the past 45 years, this Court has consistently declined to extend Bivens to new contexts."” (944)
Factual background
Prison officials at the U.S. Penitentiary in Lee County, Virginia placed Andrew Fields in solitary confinement and, during periodic checks, allegedly physically abused him. Fields sued the Bureau of Prisons and prison officials for damages under an alleged Eighth Amendment excessive‑force claim.
Procedural history
The district court dismissed Fields's complaint for lack of a Bivens cause of action. The Fourth Circuit reversed, allowing the Eighth Amendment excessive‑force claim. The Supreme Court granted certiorari, reversed the Fourth Circuit, and remanded.
Remand instructions
The case is remanded for further proceedings consistent with this opinion.