Hui v. Castaneda
Citation and Court
559 U.S. 799 (2010) — Supreme Court of the United States
Facts
Francisco Castaneda was detained by immigration authorities and developed a lesion on his penis. Despite repeated requests, Public Health Service (PHS) officers denied him a biopsy. After his release, he was diagnosed with penile cancer and died. His estate brought Bivens claims against the PHS officers for Eighth and Fifth Amendment violations.
Issue
Whether the Federal Tort Claims Act provision granting PHS officers absolute immunity from suit (42 U.S.C. § 233(a)) also forecloses a Bivens action against those officers for constitutional violations.
Holding
Yes. Section 233(a) of the Public Health Service Act makes the FTCA the exclusive remedy for personal injury claims arising from the performance of medical functions by PHS officers, and therefore forecloses a Bivens remedy against individual PHS officers.
Rule / Doctrine
Where Congress has explicitly designated an alternative remedy as the exclusive remedy for a class of claims against federal officers, that designation forecloses a Bivens action. The FTCA remedy against the United States substitutes for any direct suit against individual PHS officers, even for constitutional violations.
Significance
Hui is a significant Bivens contraction case, demonstrating that an explicit congressional exclusivity provision — even one that channels relief to a less generous remedy (suit against the government, not individual officers) — is a “special factor” that defeats Bivens. It is distinguished from Carlson v. Green, where the FTCA lacked such an explicit exclusivity clause.