title: Bivens in the End Zone: The Court Punts to Congress to Make the Right (of Action) Play
abstract: The Black Lives Matter (BLM) Movement demands equality, justice, and, perhaps most importantly, accountability. 1 Because of the abuse of power by governmental officials, particularly by those charged with law enforcement, we have seen many protests in Portland and elsewhere that invoke the First Amendment "right of the people peaceably to assemble, and to petition the Government for a redress of grievances." 2 This, of course, is one of the essential elements of the Bill of Rights, which was ra
journal: eYLS (Yale Law School)