Justice-Denied.net
Without Bivens Actions, the right to hold Federal employees personally liable for malicious, vicious and even depraved actions is severely limited under the Civil
Rights Act of 1964 and subsequent revisions. For example, a Federal, former Federal employee or non Federal employee treated with grievous and malicious indifference, would have no recourse to file suit against the parties involved in US Federal Court. A Federal Employee would only have recourse to filing against the "Department Head," such as the Attorney General. Thus, people responsible for acts of brutality and sadism in violation of the United States Constitution, would be protected by the Federal Government. This allows for a continuation of these actions against others.

Justice-Denied.net

A Bivens claim can be based on conspiracy of federal agents by showing:

(1) the existence of an express or implied agreement among the defendants to deprive someone of constitutional rights, and

(2) an actual deprivation of those constitutional rights resulting from the agreement.