On Friday, the U.S. Court of Appeals for the D.C. Circuit affirmed the dismissal of Bivens actions filed against former Attorney General WIlliam Barr and various federal law enforcement officers over their conduct in clearing protestors from Lafayette Park in June 2020.
The opinion for the panel in Buchanan v. Barr was written by Senior Judge David Sentelle (in what was likely his last opinion for the D.C. Circuit). The opinion was joined by Judges Wilkins and Walker, each of whom also wrote a separate concurring opinion.
The case was rather straightforward. Judge Sentelle summarized it as follows:
