On June 21, 1971, the Supreme Court held in Bivens v. Six Unknown Named Narcotics Agents that an implied right of action existed against federal officers for violation of one’s Fourth Amendment rights. [1] According to the court, the Constitution implied that individuals had a right to sue for monetary damages if they could prove that a federal official, acting under federal orders, subjected them to an unreasonable search or seizure. Bivens actions, then, provide an avenue for victims of constitutional violations to receive monetary redress for their grievances.  In the decade following the Bivens decision, the Court expanded the precedent to apply to infringements on the Fifth and Eighth Amendments, including individual’s rights against self-incrimination and cruel and unusual punishment, respectively, by rewarding damages in two other cases: Davis v. Passman (1979) and Carlson v. Green (1980).

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