WASHINGTON — The U.S. Supreme Court ruled that a federal inmate cannot sue corrections officers over claims of excessive force, reversing a lower court’s decision and reinforcing longstanding limitations on lawsuits against federal officials.
The June 30 decision stems from a lawsuit filed by Andrew Fields, 53, who alleged that corrections officers at USP Lee in Virginia physically assaulted him in 2021 after he attempted to go to lunch without the required movement pass, NBC News reports.
A federal judge initially dismissed the lawsuit, ruling that Fields could not pursue his claim under Bivens v. Six Unknown Named Agents — a 1971 Supreme Court decision that recognized a limited right to sue federal officers for constitutional violations. But in 2024, the 4th U.S. Circuit Court of Appeals reversed that dismissal, allowing Fields to proceed with his Eighth Amendment excessive force claim.
The Supreme Court reversed the appeals court’s decision in a unanimous opinion. The justices held that Fields’ case presented a “new context” for Bivens and that expanding the precedent to cover Eighth Amendment excessive force claims against federal prison officials was unwarranted.
The high court also cited “special factors” weighing against expanding Bivens, including the potential “negative systemic consequences for prison officials” and the fact that alternative grievance processes already exist within the Bureau of Prisons.
The ruling was unsigned and had no dissents.
Incident details disputed
According to court records, Fields — now incarcerated at a different federal facility in Florida — allegedly failed to present the required movement pass when reporting for lunch. He was then escorted to a special housing unit, where he claims he was assaulted while restrained.
The officers involved say Fields assaulted them first, an allegation he denies.
While the 4th Circuit had found no “special factors” preventing the lawsuit from moving forward, the Supreme Court emphasized that recognizing new constitutional damages claims against federal officers is a role reserved for Congress, not the courts.
