Cicchiello v. Warden

Court of Appeals for the Second Circuit·Decided August 11, 2026·No. 25-661·Unpublished

Opinion

25-661 Cicchiello v. Warden

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER

Rulings by summary order do not have precedential effect. Citation to a summary order filed on or after January 1, 2007, is permitted and is governed by Federal Rule of Appellate Procedure 32.1 and this court’s Local Rule 32.1.1. When citing a summary order in a document filed with this court, a party must cite either the Federal Appendix or an electronic database (with the notation “summary order”). A party citing a summary order must serve a copy of it on any party not represented by counsel.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 11th day of August, two thousand twenty-six.

PRESENT: STEVEN J. MENASHI, SARAH A. L. MERRIAM,

Circuit Judges,

JOHN P. CRONAN,

District Judge. *

JOAN CICCHIELLO, Plaintiff-Appellant,

v. No. 25-661 WARDEN, DANBURY, OFFICIAL CAPACITY, DANBURY FEDERAL INSTITUTE, AMUNDSON, DR., INDIVIDUAL AND OFFICIAL CAPACITY, S. MOORE, INDIVIDUAL AND OFFICIAL CAPACITY, FOISOY, LIEUTENANT, INDIVIDUAL AND OFFICIAL CAPACITY, MOSSIONIER, SUPERVISOR MAIL ROOM, INDIVIDUALLY AND OFFICIAL

* Judge John P. Cronan of the United States District Court for the Southern District of New York, sitting by designation.

CAPACITY, MAIL ROOM STAFF, INDIVIDUAL AND OFFICIAL CAPACITY, RAMOS, MR, INDIVIDUAL AND OFFICIAL CAPACITY, CLARK, MR., INDIVIDUAL AND OFFICIAL CAPACITY, Defendants-Appellees.

For Plaintiff-Appellant: FARAH MAVRAKIS (Danielle Hamilton, Bryce Collings, Hongye Zhang, on the brief), Northwestern Pritzker School of Law, Federal Appellate Litigation Clinic.

For Defendants-Appellees: No appearance.

Appeal from a judgment of the United States District Court for the District of Connecticut (Bolden, J.).

Upon due consideration, it is hereby ORDERED, ADJUDGED, and DECREED that the judgment of the district court is AFFIRMED IN PART, VACATED IN PART, and REMANDED.

Plaintiff-Appellant Joan Cicchiello appeals from the judgment dismissing three claims for damages she brought against federal officials based on alleged violations of her constitutional rights while she was incarcerated at Danbury Federal Correctional Institution. 1 See Bivens v. Six Unknown Fed. Narcotics Agents, 403 U.S. 388 (1971). Cicchiello argues that her claims were sufficiently similar to the Supreme Court’s prior Bivens cases and, in the alternative, she argues that even if her claims presented a “new Bivens context,” “special factors” did not counsel

1 Cicchiello also brought claims seeking injunctive relief, but she does not address those claims on appeal and has therefore forfeited argument that those claims should not have been dismissed.

against extending Bivens to cover her claims. Egbert v. Boule, 596 U.S. 482, 492 (2022) (quoting Ziglar v. Abbasi, 582 U.S. 120, 139 (2017)). We assume the parties’ familiarity with the facts, the procedural history, and the issues on appeal.

I

“In Bivens v. Six Unknown Fed. Narcotics Agents, [the Supreme] Court authorized a damages action against federal officials for alleged violations of the Fourth Amendment.” Id. at 486 (citation omitted). After Bivens, “the Court twice again fashioned new causes of action under the Constitution—first, for a former congressional staffer’s Fifth Amendment sex-discrimination claim, and second, for a federal prisoner’s inadequate-care claim under the Eighth Amendment.” Id. at 490-91 (citation omitted) (citing Davis v. Passman, 442 U.S. 228 (1979), and Carlson v. Green, 446 U.S. 14 (1980)).

Since the decisions in Bivens, Davis, and Carlson, the Supreme Court has “consistently refused to extend Bivens liability to any new context or new category of defendants.” Corr. Servs. Corp. v. Malesko, 534 U.S. 61, 68 (2001). The Supreme Court has “emphasized that recognizing a cause of action under Bivens is ‘a disfavored judicial activity.’” Egbert, 596 U.S. at 491 (quoting Ziglar, 582 U.S. at 135). In other words, the Court has not overruled Bivens, Davis, or Carlson. Rather, it has established a two-step test to determine whether a plaintiff may sue a federal official in a damages action for a violation of the Constitution.

“First, we ask whether the case presents ‘a new Bivens context’—i.e., is it ‘meaningfully’ different from the three cases in which the Court has implied a damages action.” Id. at 492 (alteration omitted) (quoting Ziglar, 582 U.S. at 139). “Second, if a claim arises in a new context, a Bivens remedy is unavailable if there are ‘special factors’ indicating that the Judiciary is at least arguably less equipped than Congress to ‘weigh the costs and benefits of allowing a damages action to proceed.’” Id. (quoting Ziglar, 582 U.S. at 136). At this step, “[i]f there is even a single ‘reason to pause before applying Bivens in a new context,’ a court may not recognize a Bivens remedy.” Id. (quoting Hernandez v. Mesa, 589 U.S. 93, 102 (2020)).

The Court has emphasized that these two “steps often resolve to a single question: whether there is any reason to think that Congress might be better equipped to create a damages remedy.” Id.

II

With that test in mind, we consider Cicchiello’s first claim for damages. She “alleged that prison staff failed to remedy unlivable conditions of confinement. Ms. Cicchiello alleged that when she was seventy-three years old and had a known heart condition, she was routinely exposed to temperatures exceeding 100° Fahrenheit for prolonged periods of time.” Appellant’s Br. 20. In other words, she alleged a violation of the Eighth Amendment. See Hudson v. McMillian, 503 U.S. 1, 8 (1992) (noting that “the deliberate indifference standard applied to Eighth Amendment claims involving medical care” also applies “to claims about conditions of confinement”). The district court dismissed this conditions-ofconfinement claim with prejudice, concluding that “Ms. Cicchiello’s Eighth Amendment claims arising from … allegedly overly hot conditions of confinement and sexual harassment or failure to protect her from such harassment by BOP staff present new contexts for a Bivens remedy.” App’x 12. And “the existing alternative remedies of the BOP Administrative Remedy Program for such claims precludes the Court from extending a Bivens remedy.” Id.

On appeal, Cicchiello does not argue that her Eighth Amendment claim stems from “sexual harassment or failure to protect her from such harassment by BOP staff.” Id. Therefore, we “deem[]” any argument relating to that conduct to be “abandoned.” Tarpon Bay Partners LLC v. Zerez Holdings Corp., 79 F.4th 206, 232 n.25 (2d Cir. 2023). However, on appeal, she does insist “that prison staff failed to remedy unlivable conditions of confinement.” Appellant’s Br. 20. She emphasizes that “she [is] seventy-three years old and had a known heart condition, [but] was routinely exposed to temperatures exceeding 100° Fahrenheit for prolonged periods of time.” Id.

We conclude that the district court prematurely dismissed this claim with prejudice. Cicchiello contends that, if given leave to amend, she “would … include her medical records to support her allegation that FCI Danbury was aware of her serious heart condition.” Id. at 37. If she could make that factual showing, her Eighth Amendment claim would mirror the claim brought in Carlson—a case in which the Supreme Court did permit a Bivens action to proceed.

In Carlson, the staff at a federal corrections institution were “fully apprised”

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