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Correctional Services Corporation v. Malesko
United States Supreme Court
534 U.S. 61, 122 S. Ct. 515, 151 L. Ed. 2d 456 (2001)
John E. Malesko (plaintiff) was convicted of federal securities fraud and sentenced to 18 months in prison. While in prison, Malesko was diagnosed with a heart condition that required medication and limited his ability to climb stairs. Malesko was transferred to Le Marquis Community Correctional Center (Le Marquis), a halfway house operated by Correctional Services Corporation (defendant), an organization that contracted with the Bureau of Prisons. Malesko lived on the fifth floor of Le Marquis. Correctional Services instituted a policy at Le Marquis that required all residents who lived below the sixth floor to take the stairs rather than the elevator to their rooms. Malesko was exempt from the policy due to his heart condition. Despite the exemption, an employee of Correctional Services forbade Malesko from using the elevator, and Malesko had a heart attack while climbing the stairs. Three years after his heart attack, Malesko filed a lawsuit in federal district court against several Correctional Services employees. Two years later, Malesko filed an amended complaint that named Correctional Services as a defendant and alleged that Correctional Services was negligent in refusing to allow Malesko to use the elevator at Le Marquis. Though Malesko’s complaint did not explicitly state this, the district court believed that Malesko was alleging a violation of his Eighth Amendment rights and raising his claims under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics. The district court dismissed Malesko’s complaint after holding that a Bivens claim could only be brought against individuals, not against a private entity. The court of appeals reversed the district court, holding that a Bivens claim could be brought against a private entity. The court of appeals reasoned that allowing lawsuits against private entities in addition to private individuals was necessary to effectuate the purpose of Bivens—allowing a person to seek damages for alleged constitutional violations. Correctional Services appealed, and the United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Rehnquist, C.J.)
Concurrence (Scalia, J.)
Dissent (Stevens, J.)
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