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The Hill
30-06-2025
- Politics
- The Hill
Supreme Court rejects inmate's plea for damages over excessive force claims
The Supreme Court on Monday ruled that a Virginia inmate cannot sue prison officials for damages over claims they used excessive force in breach of his 8th Amendment rights. It's the justices' latest rejection of so-called Bivens claims, which let people sue federal officials in their individual capacity for monetary damages over constitutional rights violations. 'For the past 45 years, this Court has consistently declined to extend Bivens to new contexts,' the justices wrote in an unsigned opinion. 'We do the same here.' The justices sent the case back to the U.S. Court of Appeals for the 4th Circuit for further proceedings, turning down a chance to confront the court's 1971 decision in Bivens v. Six Unknown Named Agents. The case established an implied right to seek a remedy for constitutional violations against individual federal officers despite no law authorizing such a suit, and the high court has repeatedly signaled interest in overturning it. The appeal to the justices came from prison officials facing personal liability in a series of violent assaults alleged by a Virginia inmate. The inmate, Andrew Fields, claimed several officers repeatedly 'kicked and punched' him, including with steel-toed boots, and 'rammed' his head with a police shield and into a wall. He said he was then denied access to the prison's administrative remedy program. Fields sued the individual officers in 2022 but a district court dismissed his claims, finding no Bivens remedy for excessive force. However, a split U.S. Court of Appeals for the Fourth Circuit reversed that decision, finding the 'rare' situation — the severe abuse and intentional denial of administrative relief — warranted Bivens relief. The officers asked the court to consider whether Bivens action extends to excessive force claims under the Eighth Amendment but also asked them to 'reconsider the premise' of Bivens altogether. The case could have acted as a vehicle to overturn the precedent. 'The importance of this ruling is indisputable,' the officers wrote in their petition to the court. The court's 1971 decision let a Brooklyn man seek damages against individual federal narcotics agents for violating his Fourth Amendment protections against unreasonable searches and seizures. Over the next decade, the court extended Bivens actions to employment-discrimination claims under the Fifth Amendment and cruel and unusual punishment claims alleging inadequate medical care in prison under the Eighth Amendment. However, since 1983, the court has jettisoned Bivens claims, declining to extend the remedy to other alleged constitutional violations and instead suggesting Congress should make such decisions. Most recently, Justice Clarence Thomas wrote in a majority opinion that the claims aren't valid 'in all but the most unusual circumstances.' 'The Court's unwillingness to infer new Bivens claims accords with its broader repudiation of the whole project of judicially inferring causes of action that Congress did not create,' the officers' petition reads. The solicitor general's office asked the court to summarily reverse the lower court. In recent months, several prominent Bivens claims have been filed against federal officials. Five Proud Boys leaders convicted over the Jan. 6, 2021, Capitol attack sued the Justice Department and individual FBI agents for $100 million over their prosecution earlier this month. Three of their claims are Bivens actions. Before that, Newark, N.J., Mayor Ras Baraka (D) sued interim U.S. Attorney for the District of New Jersey Alina Habba personally over his arrest last month outside a U.S. Immigration and Customs Enforcement (ICE) facility.
NBC News
30-06-2025
- NBC News
Supreme Court rules prison inmate cannot sue federal officers for alleged assault
WASHINGTON — The Supreme Court on Monday ruled that a federal prison inmate cannot sue corrections officers for an alleged assault in which he was punched, kicked and had his face slammed into a wall. The loss for inmate Andrew Fields marks the latest setback for plaintiffs seeking to hold federal officials accountable for constitutional violations. Although the Supreme Court allowed such claims in a 1971 ruling called Bivens v. Six Unknown Named Agents, it has since changed course and made it almost impossible to do so in most situations. The unsigned ruling, which had no dissents, said that if Fields' claim was allowed to move forward, it "could have negative systemic consequences for prison officials." Fields has other ways of vindicating his rights, the court added. Fields, 53, had sought to bring a "Bivens claim" arising from the 2021 incident at a federal prison in Lee County, Virginia. He is now at a different prison in Florida. The facts are disputed, with officers saying he initially assaulted them, which he denies. Fields, serving a lengthy sentence for drugs and gun offenses, alleges that the incident began when he went to lunch without bringing a required movement pass. While being moved to a special housing unit, Fields says officers punched him in the face and stomped on him. Then, once he was secured in the unit and restrained, the officers shoved his face into the wall, slammed a security shield into his back, and again punched him and kneed him in the groin, he alleges. A federal judge threw out Fields' lawsuit, which he filed without the help of a lawyer. But in a 2024 ruling, the Richmond, Virginia-based 4th U.S. Circuit Court of Appeals revived it, saying he could bring a claim under the Constitution's 8th Amendment, which protects against cruel and unusual punishment in the prison context. The Supreme Court has over several decades shown a reluctance to allow Bivens claims. In the most recent decision, the court in 2022 said Border Patrol agents could not be sued. In the 12 months after that ruling, lower courts cited it 228 times in a variety of cases against all kinds of federal officials, an NBC News investigation found. In 195 of those cases, constitutional claims were dismissed. Congress has never enacted legislation that would specifically allow federal officials to be sued individually for constitutional violations, even though it allows similar claims to be brought against state and local officials. In fact, the appeals court noted that there is "little doubt that Fields would have a viable ... claim against prison officials if he had been incarcerated at a state prison."
