Question: Which case considered eminent domain, Kelo v. City of New London or Bivens v. Six Unknown Named Agents?
Context: Scott G. Bullock is an American lawyer who focuses on property rights issues such as eminent domain and civil forfeiture.  He is President and General Counsel at the Institute for Justice, a nonprofit libertarian public interest law firm.  He represented Susette Kelo in "Kelo v. City of New London", an eminent domain case decided by the Supreme Court in 2005. Norwood, Ohio v. Horney 110 Ohio St.3d 353 was a case brought before the Ohio Supreme Court in 2006.  The case came upon the heels of "Kelo v. City of New London", in which the United States Supreme Court ruled that commercial development justified the use of eminent domain.  "Kelo" had involved the United States Constitution, while the issue in "Norwood" was the specific limitations of the Ohio State Constitution. Correctional Services Corporation v. Malesko, 534 U.S. 61 (2001), was a case decided by the United States Supreme Court, in which the Court found that implied damages actions first recognized in "Bivens v. Six Unknown Fed.  Narcotics Agents", 403 U.S. 388 (1971) should not be extended to allow recovery against a private corporation operating a halfway house under contract with the Bureau of Prisons. Dana Berliner is Litigation Director at the Institute for Justice, a public interest law firm in Arlington, Virginia founded in 1991 by Chip Mellor and Clint Bolick.  She was co-lead counsel for Susette Kelo in the landmark United States Supreme Court case "Kelo v. City of New London". United States v. Jones, 109 U.S. 513 (1883) , is an important decision by the United States Supreme Court which provides the power to take private property for public uses, in the exercise of the right of eminent domain, to the government of the United States.  However, once the government exercises of the right of eminent domain and after a fair determination of the amount of compensation, any unforeseen damage to the property as a result of activities prior to the purchase but realized only afterwards is to be compensated by the government per any legislative decree. Kelo v. City of New London, 545 U.S. 469 (2005) was a case decided by the Supreme Court of the United States involving the use of eminent domain to transfer land from one private owner to another private owner to further economic development.  In a 5–4 decision, the Court held that the general benefits a community enjoyed from economic growth qualified private redevelopment plans as a permissible "public use" under the Takings Clause of the Fifth Amendment. Constitution Park was a 2005 proposal to pursue eminent domain against the Plainfield, New Hampshire vacation estate of Supreme Court Justice Stephen Breyer, in order to construct a park commemorating the US and New Hampshire Constitutions and providing an interpretive center and lodging for visitors.  It came in response to the Supreme Court decision in "Kelo v. City of New London". Berman v. Parker, 348 U.S. 26 (1954) is a landmark decision of the United States Supreme Court that interpreted the Fifth Amendment's Takings Clause: "nor shall private property be taken for public use, without just compensation" in the Fifth Amendment of the United States Constitution.  The Court voted 8–0, holding private property could be taken for a public "purpose" with just compensation.  This case laid the foundation for the Court's later important public use cases, "Hawaii Housing Authority v. Midkiff", 467 U.S. 229 (1984) and "Kelo v. City of New London", 545 U.S. 469 (2005).  Critics of recent occurrences of eminent domain uses trace what they view as property rights violations to this case. Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971), was a case in which the US Supreme Court ruled that an implied cause of action existed for an individual whose Fourth Amendment freedom from unreasonable search and seizures had been violated by the Federal Bureau of Narcotics.  The victim of such a deprivation could sue for the violation of the Fourth Amendment itself despite the lack of any federal statute authorizing such a suit.  The existence of a remedy for the violation was implied by the importance of the right violated. Qualified immunity is a doctrine in United States federal law that arises in cases brought against state officials under 42 U.S.C Section 1983 and against federal officials under "Bivens v. Six Unknown Named Agents", 403 U.S. 388 (1971).  Qualified immunity, when applicable, shields government officials from liability, unless their actions are found to violate an individual's federal constitutional rights.  This grant of immunity is available to state or federal employees performing discretionary functions where their actions, even if later found to be unlawful, did not violate "clearly established law".
Answer: Kelo v. City of New London