Egbert-v-Boule

Civil-rights damages actions under 42 U.S.C. § 1983 reach state and local actors who violate constitutional rights under color of law; the federal-actor analog under Bivens v. Six Unknown Named Agents has been substantially narrowed by recent Supreme Court decisions

42 U.S.C. § 1983 reaches state and local actors who violate constitutional rights under color of law — a robust operative remedy. The federal-actor analog under Bivens has been substantially narrowed by Ziglar v. Abbasi (2017) and Egbert v. Boule (2022). The state-actor and federal-actor civil-rights remedies are now meaningfully asymmetric, and movement readers who lump them together miss the doctrinal divide.