In the case of Deakins et al. v. Monaghan et al., 1987, the U.S. Supreme Court ruled on whether federal courts had jurisdiction over a claim brought under Bivens v. Six Unknown Named Agents, where state officials were alleged to have conspired with private parties to violate constitutional rights. The plaintiffs claimed that their Fourth Amendment rights were violated when local law enforcement officers assisted in an unlawful search of their home conducted by Xerox Corporation's private security personnel. The court held that federal courts did not have jurisdiction over such claims because they arose from an alleged conspiracy between state and private actors rather than direct action by a federal officer or agent as required for a Bivens claim (a lawsuit for damages against federal officials violating constitutional rights). Furthermore, it was determined that there was no violation of clearly established statutory or constitutional rights which could be reasonably known by defendants at the time. This ruling clarified the limits of Bivens actions and affirmed states' sovereign immunity from certain types of lawsuits in federal court.

In the dissenting opinion for Deakins et al. v. Monaghan et al., Justice Brennan, joined by Justices Marshall and Blackmun, argued that federal courts do have jurisdiction over state officials in cases involving alleged constitutional violations under color of state law. They contended that the majority's decision to dismiss the case on procedural grounds was a departure from established precedent which allows plaintiffs to seek redress in federal court for such violations. The dissenting justices believed that this ruling could potentially limit access to justice for individuals whose rights may be violated by state officials acting under color of law, as it would require them to first exhaust all possible remedies at the state level before seeking relief in federal court - a process they deemed unnecessarily burdensome and time-consuming.