The high court has “‘consistently rebuffed’ every request—12 of them now—to find implied causes of action against federal officials for money damages under the Constitution,” and has made it clear that “expanding the Bivens remedy to a new context is an extraordinary act, that will be unavailable in most every case,” wrote U.S. District Judge Michael S. Nachmanoff.


CEO of Speaker Media and Marketing, is the "Secret Weapon of Personal Injury Lawyers and Trial Attorneys" throughout the United States. Specializing as a marketing consultant to lawyers, with a primary focus on content marketing, social media, online video and mobile marketing strategies.