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 is 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.”
Legislation in Congress that would codify Bivens claims has stalled.
