Wilson v. Hasty

Jackie Wilson, a federal prisoner, sued prison officials, including Warden Dennis Hasty, alleging they used excessive force by applying handcuffs too tightly, causing injury, in violation of the Eighth Amendment. He sought damages under the implied cause of action established in Bivens v. Six Unknown Named Agents. The district court dismissed the claim, holding that extending Bivens to this context was a new context and unwarranted under recent Supreme Court precedent. The U.S. Court of Appeals for the Tenth Circuit affirmed the dismissal. Wilson petitioned the Supreme Court for a writ of certiorari. On June 26, 2023, the Court denied the petition, declining to review the case and leaving the lower court's ruling intact.

The U.S. Supreme Court denied Wilson's petition for a writ of certiorari, allowing the dismissal of his Bivens claim to stand. No further review was granted.

Whether the federal courts should extend the Bivens implied cause of action to a federal prisoner's Eighth Amendment excessive force claim against prison officials, given the Supreme Court's expressed reluctance to recognize new Bivens contexts.

The denial reinforced the significant narrowing of Bivens remedies, leaving federal prisoners with severely limited options to seek monetary damages for constitutional violations by federal officers. It underscored the judiciary's deference to Congress for creating such causes of action and signaled continued barriers to accountability in the federal prison system.