In 1971, the U.S. Supreme Court allowed claims against federal officials who violate an individual's constitutional rights in Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971). A Bivens action is the federal equivalent of a 1983 action and would apply to employees of the Public Health Service, the CDC, and other federal agencies. Bivens actions, 1983 actions, and related actions against public health officials have similar requirements.