Goldey v. Fields, 606 U.S. 942

Andrew Fields, a federal inmate at the U.S. Penitentiary in Lee County, Virginia, was placed in solitary confinement.
Fields alleged that during routine checks, prison officials physically abused him, constituting excessive force.
Fields sued the Bureau of Prisons and individual prison officials, seeking damages for alleged Eighth Amendment violations.
The District Court dismissed the complaint, holding there was no implied Bivens cause of action for excessive force under the Eighth Amendment.
The Fourth Circuit reversed, allowing the damages claim to proceed, finding no special factors against a Bivens remedy.
The Supreme Court granted certiorari and reversed the Fourth Circuit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Bivens allows a damages remedy for Eighth Amendment excessive-force claims against federal prison officials	Fields argued that excessive force by federal officers violates his Eighth Amendment rights and warrants a damages remedy under Bivens.	Goldey argued that Bivens has never been extended to Eighth Amendment excessive-force claims and that Congress has not authorized such a remedy.	The Supreme Court held Bivens does not extend to permit an implied damages remedy for Eighth Amendment excessive-force claims against federal prison officials.

Bivens v. Six Unknown Fed. Narcotics Agents, 403 U.S. 388 (1971) (recognized implied damages action against federal officers for certain Fourth Amendment violations.)
Ziglar v. Abbasi, 582 U.S. 120 (2017) (clarified limits on new Bivens extensions; courts must be cautious in creating new implied causes of action.)
Carlson v. Green, 446 U.S. 14 (1980) (one of the few contexts where Bivens was extended beyond its original setting.)
Egbert v. Boule, 596 U.S. 482 (2022) (reaffirmed that creating remedies for constitutional violations is primarily a congressional function.)
Correctional Services Corp. v. Malesko, 534 U.S. 61 (2001) (declined to extend Bivens to allow private entity liability.)
Davis v. Passman, 442 U.S. 228 (1979) (created a Bivens remedy in a Fifth Amendment context).