Case Explained: ANTONIA ELIZABETH CARRIN as the personal representative of the estate of Raymond Marshall Carrin v. ERICA STRONG Warden

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-07-23 Docket: 4:21-cv-00486-MW-MAF The Eleventh Circuit affirmed the district court’s dismissal of the estate’s civil rights action against federal prison officials, holding that no implied cause of action exists under *Bivens* for the claims brought. The court applied the two-step framework established by the Supreme Court in *Ziglar v. Abbasi* and *Egbert v. Boule*. First, the court determined that Carrin’s claims arose in a “new context” distinct from the three existing *Bivens* precedents (*Bivens*, *Davis*, and *Carlson*). While the Eighth Amendment claim involved medical care similar to *Carlson*, the factual context differed significantly because Carrin’s Hepatitis C condition progressed over a year requiring long-term treatment, whereas *Carlson* involved an acute asthma attack occurring over a single day. Second, the court found that the existence of the Bureau of Prisons’ Administrative Remedy Program (ARP) constituted a “special factor” counseling against the expansion of the *Bivens* remedy. Under current precedent, the mere presence of an alternative remedial structure designed to address constitutional violations in federal prisons is sufficient to preclude a *Bivens* suit, regardless of whether that alternative provides monetary damages or was actually utilized by the plaintiff before his death. Consequently, the estate’s claims for compensatory and punitive damages under the Fifth and Eighth Amendments were barred, and the case remains dismissed. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.