Schweiker v. Chilicky, 487 U.S. 412 (1988), was a United States Supreme Court decision that established limitations on implied causes of action.
In this case, seriously disabled people were wrongfully being denied federal benefits (although, on appeal to an Administrative Law Judge, two-thirds had their payments restored).
Although Congress provides for the return of back-pay, no provision is made for pain and suffering or other economic losses.
The injured parties sued responsible agency personnel, under the theory that pursuant to Bivens v. Six Unknown Named Agents they could allege a private right of action for deprivation of due process.
Special factors counseling hesitation included judicial deference to a combination of: Here Congress has provided a great deal of process, and some relief, and has been otherwise silent as to a remedy, which the Court found to be enough to foreclose a Bivens remedy.