Goldey v. Fields
606 U.S. 942 (2025)
Rule of Law:
The Supreme Court will not extend the implied cause of action for damages under Bivens v. Six Unknown Federal Narcotics Agents to a new context, such as an Eighth Amendment excessive-force claim against federal prison officials, especially when Congress has legislated in the area or alternative remedial structures exist.
Facts:
- Prison officials at the U.S. Penitentiary in Lee County, Virginia, ordered Andrew Fields to be placed in solitary confinement.
- Prison officials monitored Andrew Fields while he was isolated.
- Andrew Fields alleges that during their periodic checks, officials would "physically abuse" him.
Procedural Posture:
- Andrew Fields sued the Bureau of Prisons (BOP), the prison warden, and several prison officials in the U.S. District Court for the Western District of Virginia, claiming Eighth Amendment excessive force.
- The District Court dismissed Fields's complaint, ruling that he lacked a cause of action under Bivens because the Supreme Court had not recognized a damages remedy for excessive force by BOP officers in a new context.
- Andrew Fields appealed the District Court's decision to the U.S. Court of Appeals for the Fourth Circuit.
- The Fourth Circuit, in a divided decision, reversed the District Court, concluding that Fields could proceed with his Eighth Amendment excessive-force claim for damages.
- The Fourth Circuit denied rehearing en banc.
- Prison officials, supported by the United States as amicus curiae, sought review in the U.S. Supreme Court.
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Issue:
Does an implied cause of action for damages under Bivens v. Six Unknown Federal Narcotics Agents exist for an Eighth Amendment excessive-force claim against federal prison officials?
Opinions:
Majority - Per Curiam
No, an implied cause of action for damages under Bivens does not exist for an Eighth Amendment excessive-force claim against federal prison officials. The Supreme Court has repeatedly emphasized that recognizing a cause of action under Bivens is a "disfavored judicial activity." To determine whether a Bivens claim may proceed, the Court applies a two-step test. First, the Court asks whether the case presents a "new Bivens context"—meaning it is different in a meaningful way from the few contexts where a Bivens remedy has been recognized (Fourth Amendment search and seizure, Fifth Amendment gender discrimination, Eighth Amendment inadequate medical care). This case arises in a new context as an Eighth Amendment excessive-force claim by a federal prisoner against federal prison officials. Second, if it is a new context, the Court asks whether "special factors" indicate that the Judiciary is less equipped than Congress to weigh the costs and benefits of allowing a damages action. The Court found several special factors counseling against recognizing a Bivens cause of action here: (1) Congress has actively legislated in the area of prisoner litigation but has not created a statutory cause of action for money damages; (2) extending Bivens could have negative systemic consequences for prison officials and the difficult task of running a prison; and (3) an "alternative remedial structure" already exists for aggrieved federal prisoners, even if such procedures are not as effective as an individual damages remedy. For the past 45 years, the Court has consistently declined to extend Bivens to new contexts, and it continues that practice here.
Analysis:
This case underscores the Supreme Court's consistent and strong reluctance to expand Bivens implied causes of action beyond the three original contexts. It reinforces a strict interpretation of separation of powers, placing the burden on Congress to create statutory remedies for constitutional violations by federal officials. The decision severely limits avenues for individuals to sue federal officers for constitutional torts, particularly for claims that present a "new context" or where Congress has legislated in the area, even without explicitly providing a damages remedy. This approach reflects the Court's view that creating such remedies is primarily a legislative, not judicial, function, making it increasingly difficult for plaintiffs to bring novel Bivens claims.
