Goldey v. Fields

Summary

The Court held per curiam that Bivens does not supply a damages cause of action for an Eighth Amendment excessive-force claim against federal prison officials. Such a claim presents a new Bivens context, and special factors counsel against extending the remedy: Congress has legislated extensively concerning prisoner litigation without creating a damages cause of action, extending liability could adversely affect prison operations, and alternative remedial procedures exist even if they are less effective than individual damages actions. The Court granted certiorari, reversed the Fourth Circuit’s judgment, and remanded. No separate opinions were included.