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Spivey v. Breckon - Bivens Claims Dismissed

The Fourth Circuit affirmed the dismissal of a federal prisoner's Bivens action against Bureau of Prisons employees, holding that the district court correctly concluded a Bivens remedy was unavailable. The court found that the prisoner's claims for inadequate medical care and excessive force presented new Bivens contexts beyond those recognized by the Supreme Court, and special factors counseled against extending an implied damages remedy under the Constitution.