The question
Whether the implied cause of action recognized in Bivens extends to allow an Eighth Amendment excessive-force claim for damages against federal prison officials.
Goldey v. Fields
What the Court decided
The Court reversed the Fourth Circuit and held that a federal prisoner cannot bring an Eighth Amendment excessive-force claim for damages against federal prison officials under Bivens. The claim arises in a new Bivens context, and special factors counsel against recognizing an implied cause of action. Congress has legislated in prisoner litigation without creating a statutory damages remedy, extending Bivens could harm prison operations, and alternative remedial procedures already exist for federal prisoners.
How the justices split
UnanimousPer curiam (unsigned)
Delivered by the Court
The Court applied its two-step Bivens test. It found that an Eighth Amendment excessive-force claim against federal prison officials presents a new Bivens context, different in a meaningful way from the three contexts in which the Court has recognized a Bivens remedy. It found special factors counseling against an implied cause of action: Congress has actively legislated in prisoner litigation without enacting a statutory damages remedy, extending Bivens could have negative consequences for prison operations, and alternative remedial procedures already exist for federal prisoners. For 45 years the Court has consistently declined to extend Bivens to new contexts, and prescribing a cause of action is a job for Congress.
How we know · 5 sourced claims
The Court held that Bivens does not extend to allow an Eighth Amendment excessive-force claim for damages against federal prison officials.
Source: syllabus, Held
The decision was issued Per Curiam and reversed and remanded the Fourth Circuit's judgment, reported at 109 F. 4th 264.
Source: syllabus, Held
The Court found the case arises in a new Bivens context and that special factors counsel against recognizing an implied cause of action.
Source: syllabus, Held
Congress has actively legislated in prisoner litigation but has not enacted a statutory cause of action for money damages.
Source: syllabus, Held
The Court noted that for 45 years it has consistently declined to extend Bivens to new contexts.
Source: syllabus, Held