Bivvens not extended to cover a federal agent's preventing the plaintiff from leaving a parking lot and then using excessive force to effect an unlawful seizure.
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Not written by a barrister. The name was thought up by a second-year American law student sitting in a coffeehouse in Manhattan. Neither an authoritative statement of the law nor legal advice.
Don't rely. Quick work.