Spivey v. Breckon

When Mandriez Spivey tried to vindicate his rights to medical care and to be free from the use of excessive force in federal prison, the district court dismissed his claims, finding that he had no cause of action under Bivens v. Six Unknown Named Agents. The MacArthur Justice Center took his case to fight for him, and people like him in federal prison, to have the opportunity to vindicate their rights in court.

Mandriez Spivey brought a suit challenging violations of his Eighth Amendment rights by federal prison officials who denied or delayed care for his profuse rectal bleeding and stomach pain, serious dental conditions, severe depression, and injuries sustained as a result of officers’ use of force. The district court dismissed his claims, holding that he had no cognizable cause of action under Bivens v. Federal Bureau of Prisons even though the Supreme Court and the Fourth Circuit have repeatedly acknowledged that Bivens extends to Eighth Amendment medical care claims. The MacArthur Justice Center appealed the district court’s ruling, arguing that the district court’s holding contravenes binding precedent.

Meanwhile, Mr. Spivey also brought an Eighth Amendment challenge to officers’ use of excessive force, whereby they put tight restraints around Mr. Spivey’s wrists, ankles, and sides and forced him to kneel before repeatedly smashing his head into a wall, digging a shield into his back and legs, and stepping on his toes. Here, too, the district court dismissed Mr. Spivey’s claims, finding that he did not have a cause of action under Bivens. But the Fourth Circuit’s recent ruling in Fields v. Federal Bureau of Prisons—decided after the district court dismissed Mr. Spivey’s claims—makes clear that Bivens extends to Mr. Spivey’s excessive force claims.