Vickers v. Brennan

CourtDistrict Court, N.D. Ohio
DecidedFebruary 19, 2025
Docket1:24-cv-01642
StatusUnknown

This text of Vickers v. Brennan (Vickers v. Brennan) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Vickers v. Brennan, (N.D. Ohio 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO EASTERN DIVISION

DAVID WAYNE VICKERS, ) CASE NO. 1:24 CV 1642 ) Plaintiff, ) JUDGE DAVID A. RUIZ ) v. ) ) MEMORANDUM OF OPINION U.S. ATTORNEY ) AND ORDER BRIDGET M. BRENNAN, et al., ) ) Defendants. )

Pro se Plaintiff David Wayne Vickers, an inmate in USP Tucson, filed this Bivens1 action against former United States Attorney Bridget M. Brennan, and Assistant United States Attorney Brian McDonough. Plaintiff claims the Defendants denied him due process under the Fifth Amendment in their responses to his Rule 60(b) Motion challenging the denial of his Motion to Vacate under 28 U.S.C. § 2255. He asks the Court to declare his assertions in this Complaint to be true, enjoin the Defendants from inserting information into his future Motions and award him monetary damages. Although pro se pleadings are liberally construed, Boag v. MacDougall, 454 U.S. 364, 365 (1982) (per curiam); Haines v. Kerner, 404 U.S. 519, 520 (1972), the Court is required to dismiss an in forma pauperis action under 28 U.S.C. §1915(e) if it fails to state a claim upon which relief can be granted, or if it lacks an arguable basis in law or fact. Neitzke v. Williams, 490 U.S. 319 (1989); Lawler v. Marshall, 898 F.2d 1196 (6th Cir. 1990); Sistrunk v. City of

1 Bivens v. Six Unknown Agents, 403 U.S. 388 (1971). Strongsville, 99 F.3d 194, 197 (6th Cir. 1996). A claim lacks an arguable basis in law or fact when it is premised on an indisputably meritless legal theory or when the factual contentions are clearly baseless. Neitzke, 490 U.S. at 327. A cause of action fails to state a claim upon which relief may be granted when it lacks “plausibility in the Complaint.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 564 (2007). A pleading must contain a “short and plain statement of the claim showing that the pleader is entitled to relief.” Ashcroft v. Iqbal, 556 U.S. 662, 677-78 (2009). The factual allegations in the pleading must be sufficient to raise the right to relief above the speculative level on the assumption that all the allegations in the Complaint are true. Twombly, 550 U.S. at 555. The

Plaintiff need not include detailed factual allegations, but must provide more than “an unadorned, the-Defendant-unlawfully-harmed-me accusation.” Iqbal, 556 U.S. at 678. A pleading that offers legal conclusions or a simple recitation of the elements of a cause of action will not meet this pleading standard. Id. In reviewing a Complaint, the Court must construe the pleading in the light most favorable to the Plaintiff. Bibbo v. Dean Witter Reynolds, Inc., 151 F.3d 559, 561 (6th Cir.1998). As an initial matter, this Court must first determine whether Plaintiff can bring these claims in a Bivens action. The Supreme Court has explicitly recognized only three contexts in which a private right of action for damages may be properly brought under Bivens against federal officials for constitutional violations: (1) under the Fourth Amendment for a violation of the

prohibition against unreasonable searches and seizures of a private citizen’s residence, Bivens, 403 U.S. at 389, 397; (2) under the Fifth Amendment Due Process Clause for gender discrimination, Davis v. Passman, 442 U.S. 228, 230–31, 248-49 (1979); and (3) under the Eighth Amendment for failing to provide adequate medical treatment to a prisoner, Carlson v. Green, 446 U.S. 14, 16 n.1, 19 (1980). In these cases, the Supreme Court implied a cause of action against federal officers for violations constitutional rights. Carlson v. Green, 446 U.S. 14, 100 S.Ct. 1468, 64 L.Ed.2d 15 (1980); Davis v. Passman, 442 U.S. 228, 99 S.Ct. 2264, 60 L.Ed.2d 846 (1979); Bivens v. Six Unknown Fed. Narcotics Agents, 403 U.S. 388, 91 S.Ct. 1999, 29 L.Ed.2d 619 (1971). The Supreme Court reasoned that sometimes individual-rights violations could be redressed only by damages, and they had the power to create such actions unless Congress limited them. Bivens, 403 U.S. at 397, 91 S.Ct. 1999. Recent developments, however, have altered that line of reasoning. What began as a presumption in favor of creating an implied right of action has developed into a strong

presumption against it. The Supreme Court has not recognized a new Bivens action in the 40 years since Carlson and over that time period has repeatedly declined to create such actions. See, e.g., Ziglar v. Abbasi, 582 U.S. 120, 135 (2017). In fact, the Court has renounced the presumption of implied remedies, stating that in most cases Congress, rather than the Courts, should decide whether a cause of action exists for violations of the Constitution. Id. “[E]xpanding the Bivens remedy is now a ‘disfavored’ judicial activity.” Id. Therefore, in determining whether a cause of action can proceed under Bivens, the Court must engage in a two-step inquiry. Egbert v. Boule, 596 U.S. 482, 492 (2022); Hernandez v. Mesa, 140 S. Ct. 735, 743 (2020). First, the Court must determine whether the case falls within one of the three recognized causes of action or whether it presents a claim that arises in a “new

[Bivens] context” or involves a “new category of Defendants.” In other words, is it “meaningful[ly]” different from the three cases in which the Court has implied a damages action. If this is the case, then it is a new context for Bivens purposes. Id. If a claim presents a new Bivens context, then the Court must determine whether “‘special factors counsel[ ] hesitation’ in recognizing the new claim.” Callahan v. Fed. Bureau of Prisons, 965 F.3d 520, 524 (6th Cir. 2020); Egbert, 596 U.S. at 491. Such factors include “whether alternative processes exist for protecting the right,” “whether existing legislation covers the area,” and “separation-of-powers principles”—e.g., whether recognizing a new claim would “interfer[e] with the authority of the other branches and whether the judiciary can competently weigh the costs and benefits at stake.” Callahan, 965 F.3d at 524; Hernandez, 140 S. Ct. at 743. Finally, a Court may not fashion a Bivens remedy if Congress already has provided, or has authorized the Executive Branch to provide, “an alternative remedial structure.” Ziglar, 137 S.Ct.

at 1858; Egbert, 596 U.S. at 493. If there are alternative remedial structures in place, that alone is reason to restrict the exercise of judicial power to infer a new Bivens cause of action. Id.

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Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Imbler v. Pachtman
424 U.S. 409 (Supreme Court, 1976)
Parklane Hosiery Co. v. Shore
439 U.S. 322 (Supreme Court, 1979)
Montana v. United States
440 U.S. 147 (Supreme Court, 1979)
Davis v. Passman
442 U.S. 228 (Supreme Court, 1979)
Carlson v. Green
446 U.S. 14 (Supreme Court, 1980)
Boag v. MacDougall
454 U.S. 364 (Supreme Court, 1982)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
New Hampshire v. Maine
532 U.S. 742 (Supreme Court, 2001)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Abdul Al-Bari v. Steven Winn and Jimmy Creecy
907 F.2d 150 (Sixth Circuit, 1990)
Steven Craig Cooper v. Larry E. Parrish
203 F.3d 937 (Sixth Circuit, 2000)

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Vickers v. Brennan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vickers-v-brennan-ohnd-2025.