# Park Dean Kauffman Gaila M. Kauffman v. Anglo-American School of Sofia, an Unincorporated Association

> Court of Appeals for the D.C. Circuit · July 12, 1994 · 28 F.3d 1223

URL: https://www.frixlaw.com/law-library/cases/9487011

## Case

- **Full name:** Park Dean KAUFFMAN; Gaila M. Kauffman, Appellants, v. ANGLO-AMERICAN SCHOOL OF SOFIA, an Unincorporated Association, Appellee
- **Court:** Court of Appeals for the D.C. Circuit
- **Decided:** July 12, 1994
- **Citations:** 28 F.3d 1223; 307 U.S. App. D.C. 356; 1994 U.S. App. LEXIS 17008; 1994 WL 326786
- **Precedential status:** Published
- **Opinion:** Concurrence by Sentelle
- **Judges:** Mikva, Williams, Sentelle
- **Cited by:** 71 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/9487011

## How later opinions describe it (automated extraction)

- holding that Bivens does not apply to private companies
- holding that, like federal agencies, unincorporated associations may not be sued under Bivens
- holding that a Bivens action may not be brought against a private, non-individual entity
- holding no Bivens actions against private entities

## Opinion text

SENTELLE, Circuit Judge,
concurring:
I am in complete agreement with the opinion of the court, and write separately to emphasize what the court is not doing. Mrs. Kauffman sues the Anglo-American School on the basis that its discharge of her husband creates some separate cause of action in her. Though we do not reach the question in light of our disposition of the case on other threshold grounds, I do not understand the court to be creating any precedent for or lending any credence to the notion that an allegedly unlawful firing of one family member creates any claim for relief on the part of another family member that would survive a motion for dismissal under Fed.R.Civ.P. 12(b)(6).

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/9487011. Public record. Not legal advice.