The Supreme Court granted certiorari to hear Egbert v. Boule, 596 U.S. ___ (2022), in November 2021, which was expected to review extensions of Bivens related remedies. The case involved a lawsuit filed by Robert Boule, the owner of an inn at the U.S.-Canada border against U.S. Border Patrol agent Erik Egbert related to a 2014 incident. In the incident, after Boule asked Egbert to leave his property when Egbert had approached a Turkish man about his immigration status, Egbert pushed Boule to the ground. Boule complained to the Border Patrol, which in turn led Egbert to prompt the IRS to investigate Boule. Boule claimed his First and Fourth Amendment rights were violated under Bivens. The district court found against Boule asserting his claims were an inappropriate extension of Bivens, but the Ninth Circuit reversed.
