Feb. 20, 2026
Civil liability of ICE and border patrol agents for excessive force
Bivens actions, once a key tool for victims of federal excessive force, are now largely foreclosed in immigration and similar contexts after the Supreme Court's 2022 Boule v. Egbert decision, leaving plaintiffs and their lawyers to navigate a dramatically narrowed path for holding federal agents accountable.
Douglas S. Gilliland
Phone: (619) 878-1580
Email: doug@thegillilandfirm.com
Univ of Oregon SOL; Eugene OR
Douglas S. Gilliland is a civil rights mediator from San Diego, California. For over 30 years he litigated Section 1983, Bane Act and FTCA cases. Prior to Boule, he litigated Bivens excessive force and false arrest cases against the FBI, ICE, Border Patrol, Customs and Border Protection and DHS. He is a panel mediator with the United States District Court for the Central District of California and the Los Angeles Superior Court's MVP Panel. He mediates civil rights cases exclusively.
Challenging cases can bring gratification. Yet they can
also lead to frustration and a common lament, "Why did I take this case?" Case
selection is sometimes the most important part of a plaintiff's practice.
Civil rights cases are challenging enough. Federal cases are often defend...
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