Background
Anthony Glenn James filed a complaint in the United States District Court for the District of South Carolina seeking relief under Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics. The district court accepted a magistrate judge’s recommendation and denied James’s complaint. James appealed the order to the Fourth Circuit.
The court’s reasoning
The court reviewed the record and found no reversible error. It determined that James failed to allege sufficient facts showing that his claims constituted constitutional violations recognized by Bivens. Additionally, the court held that Appellees Christopher Lietzow and Carra Henderson are protected by absolute prosecutorial immunity.
James fails to allege sufficient facts showing that his claims constitute constitutional violations recognized by Bivens.
James v. Sonnendecker, No. 25-2425 (4th Cir. 2026)
What it means going forward
The decision reinforces the high bar for pleading Bivens claims and confirms that federal prosecutors retain absolute immunity from suit for actions within their prosecutorial role.