Gutting Bivens: How the Supreme Court Shielded Federal Officials from Constitutional Litigation

“No man in this country is so high that he is above the law. . . . All officers of the government, from the highest to the lowest, are creatures of the law, and are bound to obey it. . . . [And the] Courts of justice are established, not only to decide upon the controverted rights of the citizens as against each other, but also upon rights in controversy between them and the government.” —United States v. Lee (1882)