Generally, the appropriate private cause of action against officials who, under color of federal law, violate someone's constitutional rights is to seek damages in a Bivens lawsuit. When national security issues are involved, however, the federal courts regularly bar relief under Bivens. As the recent appellate decisions in Lebron v. Rumsfeld, Padilla v. Yoo, Doe v. Rumsfeld, and Vance v. Rumsfeld display, even when the rights violations involve torture and similar acts, which “shock the conscience,” there is no Bivens relief available to plaintiffs.