This Comment examines the current state of the Bivens doctrine in light of the Supreme Court's recent holding in Minneci v. Pollard. The author argues that, rather than another example of the Court&'s wariness toward "extending" Bivens to a "new context" Minneci represents a subtle but significant retreat for the doctrine itself. After critiquing the Court's application of the traditional two-step test for assessing potential Bivens claims, the Comment concludes by exploring what the Minneci Court's reasoning may portend for the future of Bivens.

Thomas Frampton, Bivens’s Revisions: Constitutional Torts After Minneci v. Pollard, 100 California Law Review, 1711–1744 (2012).