significant deterrence and compensation", despite acknowledging that these officials were "act[ing] under color of federal law". Reichle v. Howards, Wood v. Moss, Ziglar v. Abbasi, Hernandez v. Mesa, Hernandez v. Mesa, Brownback v. King, Egbert v. Boule, Subsequent developments Scholarship on Bivens success rate According to Alexander A. Reinert, law professor at the Benjamin N. Cardozo School of Law of Yeshiva University, many attorneys assumed Bivens claims were far less successful than other civil rights litigation. However, Reinert's research showed outcomes for plaintiffs more promising than had been assumed: "Depending on the procedural posture, presence of counsel, and type of case," success ranged from "16% to more than 40%," and that "when Bivens claims fail, it very rarely is because of the qualified immunity defense." Egbert v. Boule The Supreme Court granted Egbert v. Boule, 596 U.S. ___ (2022), in November 2021, which is expected to review extensions of Bivens related remedies. The case involves a lawsuit filed by Robert Boule, the owner of an inn at the U.S.-Canada border against U.S. Border Patrol agent Erik Egbert related to a 2014 incident. In the incident, after Boule asked Egbert to leave his property when Egbert had approached a Turkish man about his immigration status, Egbert pushed Boule to the ground. Boule complained to the Border Patrol, which in turn led Egbert to prompt the IRS to investigate Boule. Boule claimed his First and Fourth Amendment rights were violated under Bivens. The district court found against Boule asserting his claims were an inappropriate extension of Bivens, but the Ninth Circuit reversed. In a 6-3 decision, the Supreme Court of the United States decided that the authority of the court to find a course of action under Bivens does not extend to Robert Boule claim of excessive force under the Fourth Amendment to the United States Constitution and his First Amendment retaliation claim. See also Qualified immunity List of United States Supreme Court cases, volume 403 References Sources External links Casebrief Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics a provided by Bloomberg Law's Law Cases & Case Briefs for Students United States Supreme Court cases Implied constitutional cause of action case law United States Fourth Amendment case law Drug Enforcement Administration litigation 1971 in United States case law United States Supreme Court cases of the Burger Court 1970s in Brooklyn