from taking legitimate adverse personnel actions. See id. at 445, 108 S.Ct. 668. Further, because multiple jurisdictions had concurrent jurisdiction over actions challenging personnel decisions, there was a wide variation in decisions regarding the same or similar matters. See id. Accordingly, the CSRA was designed to eliminate this problem as well. See id. The Supreme Court examined the availability of a Bivens action in a federal employment context in Bush v. Lucas, 462 U.S. 367, 103 S.Ct. 2404, 76 L.Ed.2d 648 (1983). In Bush, the Supreme Court determined that federal employment constituted a “special factor” warranting refusal to recognize a First Amendment Bivens claim asserted by a federal employee. See Bush, 462 U.S. at 378-80, 103 S.Ct. 2404; Zimbel r.1983) (per curiam) (<HOLDING>). Accordingly, the district court correctly
holding that if adequate administrative remedies are available it is improper to seek relief in court before those remedies are exhausted holding that employees of county jail that housed federal prisoners pursuant to contract with the federal government were not federal employees even though county jail had to comply with federal rules and regulations holding that where statutory remedies exist private employees do not have a private cause of action for violation of state constitutional rights holding that claims by federal employee were barred under bush even though one claim was against coworkers because the purpose of denying a private cause of action to federal employees is to ensure that they do not bypass comprehensive and carefully balanced statutory and administrative remedies in order to seek direct judicial relief holding that comprehensive administrative scheme signals that congress did not intend to permit service members to assert a private cause of action in federal court under the mwpa