Correctional Services Corp. v. Malesko

Correctional Services Corporation v. Malesko, 534 U.S. 61 (2001), was a case decided by the United States Supreme Court, in which the Court found that implied damages actions first recognized in Bivens v. Six Unknown Named Agents should not be extended to allow recovery against a private corporation operating a halfway house under contract with the Bureau of Prisons.

A Bivens action is a civil rights violation suit against the government. The Supreme Court limited this court-invented private right of action to exclude corporate defendants like Correctional Services Corporation. Plaintiff's actions against the individual employees were barred by the statute of limitations because the names of the John Doe defendant prison guards (esp. Jorge Urena) were not known to the plaintiff.