Goldey, Associate Warden, et al. v. Fields
No. 24-809 · Decided June 30, 2025 · reversed and remanded
Does *Bivens v. Six Unknown Fed. Bivens does not extend to allow an Eighth Amendment excessive-force claim for damages against federal prison officials.
Vote & lineupPer Curiam
The question
Does *Bivens v. Six Unknown Fed. Narcotics Agents* extend to allow a claim for money damages based on Eighth Amendment excessive-force violations by federal prison officials? The Court must determine if this scenario constitutes a "new context" under existing precedent. If so, the Court must decide whether special factors counsel against recognizing an implied cause of action.
Petitioner's argument
- not stated.
Respondent's argument
- Respondent argued that he could proceed with an Eighth Amendment excessive-force claim for damages against federal prison officials.
- Respondent contended that no "special factors counseled against extending Bivens" in this context.
The decision
- The Court held that *Bivens v. Six Unknown Fed. Narcotics Agents* does not extend to allow an Eighth Amendment excessive-force claim for damages against federal prison officials.
- The Court applied a two-step test: first, asking if the case presents a "new Bivens context" by being "different in a meaningful way" from recognized remedies; and second, asking if "special factors" indicate the Judiciary is less equipped than Congress to weigh costs and benefits.
- Relying on *Bivens*, *Davis v. Passman*, *Carlson v. Green*, and *Ziglar v. Abbasi*, the Court determined this case arises in a new context.
- The Court found that "special factors" anchored in "separation-of-powers principles," as cited in *Egbert v. Boule* and *Ziglar v. Abbasi*, counsel against recognizing the claim.
- One such factor is that Congress has actively legislated in prisoner litigation but has not enacted a statutory cause of action for money damages, citing *Ziglar v. Abbasi*.
- The Court reasoned that extending *Bivens* could have negative systemic consequences for the "inordinately difficult undertaking" of running a prison, invoking *Turner v. Safey*.
- The Court noted that an "alternative remedial structure" already exists for federal prisoners, citing *Ziglar v. Abbasi* and *Correctional Services Corp. v. Malesko*.
- Following *Egbert v. Boule*, the Court concluded that alternative procedures counsel against allowing *Bivens* suits even if those procedures are "not as effective as an individual damages remedy."