This remedy has also been applied to the Fifth Amendment’s equal protection component, Davis v. Passman, 442 U.S. 228, 248, 99 S.Ct. 2264, 2278, 60 L.Ed.2d 846 (1979), and the Eighth Amendment’s prohibition against cruel and unusual punishment, Carlson v. Green, 446 U.S. 14, 24-25, 100 S.Ct. 1468, 1474-75, 64 L.Ed.2d 15 (1980). The United States Supreme Court has come to refer generically to causes of action for damages for the violation of constitutional rights as Bivens-type causes of action. See Bush v. Lucas, 462 U.S. 367, 377, 103 S.Ct. 2404, 2411, 76 L.Ed.2d 648 (1983) (referring to Bivens, Davis, Carlson, and other cases seeking damages for violation of constitutional righ d 431 (1992); Provens v. Stark County Bd. of Mental Retardation, 64 Ohio St.3d 252, 594 N.E.2d 959 (1992) (<HOLDING>). Other jurisdictions have based their
holding that private rights of action to enforce federal law must be created by congress courts may not create a cause of action absent statutory intent holding that where statutory remedies exist private employees do not have a private cause of action for violation of state constitutional rights recognizing cause of action against federal officials for violation of constitutional rights recognizing private right of action holding that a private right of action exists