Summary
This Supreme Court per curiam opinion addresses whether an implied cause of action under Bivens extends to Eighth Amendment excessive-force claims against federal 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.
Topics
Practice areas
Questions Presented
- Whether Bivens extends to an Eighth Amendment excessive‑force claim against federal prison officials
- Whether special factors counsel against recognizing such a 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.” (at 491)
“For 45 years, this Court has consistently declined to extend Bivens to new contexts.” (at 490–491)
Factual background
Prison officials at the U.S. Penitentiary in Lee County, Virginia placed Andrew Fields in solitary confinement and, during periodic checks, physically abused him. Fields sued the Bureau of Prisons and prison officials for damages under the Eighth Amendment.
Procedural history
The District Court for the Western District of Virginia dismissed Fields's Eighth Amendment excessive‑force claim for lack of a Bivens cause of action. The Fourth Circuit reversed in part, allowing the claim to proceed. The Supreme Court granted certiorari and reversed the Fourth Circuit.
Remand instructions
The case is remanded for further proceedings consistent with this opinion.