A different take on the future of Bivens: Folks around talking online about whether the Democrats might include codification of Bivens to the legislative agenda. It is an easy fix (add a few words to existing § 1983 or copy a new statute on that existing provision). It fells well with one thing people hope to see (limiting ICE). And it might gain bipartisan support, as Republicans envision President Ossoff and the need to sue that administration for damages.