822 F.3d 248
6th Cir.2016Background
- Koprowski, a federal inmate working in prison food service, fell from a ladder on Nov. 23, 2009, sustaining a compression fracture of L3 and ongoing pain and disability.
- He alleges prison medical and custody staff were deliberately indifferent to his serious medical needs (Eighth Amendment) by delaying diagnostics, denying MRIs/specialized care, punishing inability to work, and coercing him to surrender mobility aids.
- Koprowski pursued prison administrative remedies and IACA benefits (lost wages and potential post-release impairment compensation) before filing a Bivens suit against six federal prison officials for monetary damages.
- The district court dismissed his Eighth Amendment Bivens claim, holding the Inmate Accident Compensation Act (IACA) is the exclusive remedy for work-related prison injuries, and dismissed his First, Fifth, and Fourteenth Amendment claims (exhaustion/forfeiture grounds).
- The Sixth Circuit reverses as to the Eighth Amendment Bivens claim: it holds the IACA (and the BOP grievance ARP) do not displace a Bivens damages remedy for alleged deliberate indifference in prison medical care; other constitutional claims remain dismissed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the IACA displaces an Eighth Amendment Bivens damages remedy for work-related prison injuries | IACA does not substitute for Bivens; plaintiff may pursue constitutional damages for deliberate indifference | IACA (workers’ compensation) is the inmate’s exclusive monetary remedy for workplace injuries and therefore displaces Bivens | IACA does not displace a Bivens Eighth Amendment claim; reversal as to that claim |
| Whether the BOP Administrative Remedy Procedure (ARP) provides an adequate alternative to Bivens | ARP is inadequate to replace money-damages relief | ARP provides an administrative avenue and thus precludes Bivens damages | ARP does not displace a Bivens damages remedy (McCarthy/Carlson precedent controls) |
| Whether any "special factors" counsel hesitation in recognizing Bivens here | No special factors; Carlson allows prisoner Eighth Amendment Bivens suits; qualified immunity suffices | Special factors and policy concerns counsel against extending Bivens where alternative schemes exist | No new special factors found; Carlson remains controlling; Bivens available |
| Whether prison officials enjoy absolute immunity via the IACA | Plaintiff: no absolute immunity; qualified immunity applies only | Defendants/dissent: IACA exclusivity (and Hui reasoning) grants immunity from suit | Court declines to address new absolute-immunity argument sua sponte and rejects the contention absent clear statutory exclusivity; qualified immunity remains the presumptive protection |
Key Cases Cited
- Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, 403 U.S. 388 (implied damages remedy for Fourth Amendment violations)
- Carlson v. Green, 446 U.S. 14 (Eighth Amendment Bivens damages available to federal prisoners for deliberate indifference)
- United States v. Demko, 385 U.S. 149 (IACA is exclusive remedy for common-law torts against the United States for inmate workplace injuries)
- Corr. Servs. Corp. v. Malesko, 534 U.S. 61 (limits on expanding Bivens; recognition that Bivens remains for federal prisoners against individual officers)
- Hui v. Castaneda, 559 U.S. 799 (statutory exclusivity can bar suits against individual officials when statute provides an exclusive remedy)